Is there really a royal road around debt-discharge income?
Article Abstract:
Unsecured nonrecourse notes may be used to satisfy debt obligations but not necessarily without recognition of gain and income taxation. Analysis of IRC sections 1272-1274 and relevant IRS regulations may lead to the conclusion that the worst tax consequence could be treating the issue price as the fair market value of the paid debt. However, the original issue discount rules may have more taxing consequences for discharge of indebtedness income.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1998
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Revenue Ruling 95-41: a favorable analysis for allocating partnership nonrecourse debt
Article Abstract:
The IRS's Revenue Ruling 95-41 on allocation of nonrecourse liabilities favors taxpayers by providing ways to avoid recognizing gains on encumbered property contributions and later debt paydowns. The ruling clarifies issues concerning the second and third tier allocations and the effects of the partners' choice of allocation methods.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1996
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Impact fees and publicly dedicated improvements: are they really nondepreciable intangibles?
Article Abstract:
The authors argue that the exclusion of dedicated improvements and impact fees as basis for property is inconsistent with tax law under IRC sections 263A and 460.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 2001
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