Abstracts - faqs.org

Abstracts

Law

Search abstracts:
Abstracts » Law

Corporate debt restructuring: stock-for-debt exchanges and other workout scenarios

Article Abstract:

Congress, in Section 108(e)(8) of the Bankruptcy Tax Act of 1980, indirectly permitted corporations to trade stock for debt without incurring cancellation of debt (COD) income. This stock-for-debt exception is important to corporate planners seeking to minimize both COD income and attribute reduction. However, a 1990 amendment limits the exception's applicability to disqualified stock such as stock with a fixed redemption rate. The IRS proposed regulations for stock-for-debt restructurings, including controversial safe-harbor tests for stock transfers, which will cover acquisitions occurring after Mar 21, 1991.

Author: Silverman, Mark J., Keyes, Kevin M.
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1992
Debt financing (Corporations), Debt financing, Debt equity conversion

User Contributions:

Comment about this article or add new information about this topic:

CAPTCHA


Corporate distributions: handling liabilities in excess of the fair market value of property remains unresolved

Article Abstract:

The Tax Reform Act of 1986 (TRA '86) made corporations liable to taxation for distributions of property in excess of the fair market value. TRA '86 repealed the rule against the double taxation of corporations for property distributions. Liquidating distribution, liquidating sale, and nonliquidating distribution of property are all recognized as forms of gain by corporations under TRA '86. However, the Technical and Miscellaneous Revenue Act of 1988 corrected TRA '86's rule concerning tax liability for distributions.

Author: Randall, Boyd C., Stewart, Dave N.
Publisher: Warren, Gorham & Lamont, Inc.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1992
Liabilities (Accounting), Corporate distributions, Liquidation

User Contributions:

Comment about this article or add new information about this topic:

CAPTCHA



Subjects list: Taxation, Laws, regulations and rules, Corporate taxes, Corporations
Similar abstracts:
  • Abstracts: Middle Rio Grande regional water resource planning: the pitfalls and the promises. Transportation of transuranic nuclear waste to WIPP: a reconsideration of truck versus rail for two sites
  • Abstracts: AAA President Slate focuses ADR challenges. ADR in the new century. Mediation year 2051? Given the mind-boggling advances in high technology, is it possible that someday a smart software program would replace mediators?
  • Abstracts: Presidential administration. Federal courts - proposed changes to the Ninth Circuitt and the federal courts of appeals
  • Abstracts: Storm over Niagara: a catalyst in reshaping government in the United States and Canada during the Progressive Era
  • Abstracts: Planning for Educational Benefits after the Greensboro Case. Excluding Qualified Defined Benefit Plan Insured Incidental Death Benefits from the Participant's Gross Estate - Minority and Non-Stockholders
This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.
Some parts © 2023 Advameg, Inc.