News & Analysis as of

Income Taxes › Internal Revenue Service › Debt

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Jones Day

Internal Revenue Service Alters Its View on Section 355 Spin-Offs

Jones Day on

The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more

Rivkin Radler LLP

Sale of Mortgaged Property – Amount Realized or COD Income

Rivkin Radler LLP on

Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more

Foster Garvey PC

There Is a Santa Claus After All – Lawmakers Deliver a Wonderful Holiday Gift to Businesses and Their Owners in a Time of Need

Foster Garvey PC on

The Consolidated Appropriations Act, 2021 - In a bipartisan effort, H.R. 133-116th Congress: Consolidated Appropriations Act, 2021 (the "Consolidated Appropriations Act, 2021") overwhelmingly passed both the House and the...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Troutman Pepper

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Troutman Pepper on

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

Dechert LLP

New Proposed Regulations Increase Scrutiny on Related-Party Debt

Dechert LLP on

The U.S. Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently issued proposed regulations (the “New Proposed Regulations”) governing the federal income tax treatment of debt between certain related...more

Eversheds Sutherland (US) LLP

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Eversheds Sutherland (US) LLP on

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Eversheds Sutherland (US) LLP

Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes

Eversheds Sutherland (US) LLP on

On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC § 385 (the Proposed Regulations) that are intended to combat perceived concerns associated with indebtedness between...more

Ballard Spahr LLP

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

Ballard Spahr LLP on

The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

Miller & Martin PLLC

IRS Creates New Disregarded Entity Exclusion from Debt Cancellation Income

Miller & Martin PLLC on

The IRS has announced a new safe harbor from the discharge of debt income rules. Debt that is cancelled, discharged or forgiven is generally taxable as income, but there are exceptions. Under one exception, certain...more

11 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide