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Debt Tax Returns

Rivkin Radler LLP

Intercompany Loan Treated As Constructive Distribution and Contribution

Rivkin Radler LLP on

Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more

Rivkin Radler LLP

Debt or Equity? The Never-Ending Question For Closely Held Businesses

Rivkin Radler LLP on

What Was Intended? Transactions between commonly controlled, closely held businesses are often conducted in an informal manner. This is unfortunate because, in the absence of documentation, it is sometimes difficult to...more

Rivkin Radler LLP

Shared Appreciation Interest: Debtor-Creditor or Partners?

Rivkin Radler LLP on

When is a loan not a loan? When it’s something else – for example, equity. This is one of those pesky facts and circumstances issues that plague courts, taxpayers, and tax advisers to no end. Debt- On one end of the...more

Rivkin Radler LLP

Selling Your Business? Take the Money But Defer the Tax?

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Sale of the Business- Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more

Farrell Fritz, P.C.

Related Company Transfers: Debt Or Equity? Capitalized Or Expensed?

Farrell Fritz, P.C. on

It is often difficult to determine the proper tax treatment for the transfer of funds among related companies, especially when they are closely held, in which case obedience to corporate formalities may be found wanting. ...more

Lowndes

Worthless Debt Deduction – A Cautionary Tale

Lowndes on

For partnership, individuals and other types of taxpayers that are not in the business of making loans, the main avenue for tax relief when a loan goes bad is Section 166 – the bad debt deduction. In order to claim this...more

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