Evaluating the many options that exist for restructuring partnership debt

Article Abstract:

Partnerships borrow money for their financial projects. However, some of them encounter financial problems and as a consequence, need to restructure their debt program. Because laws concerning partnership debt are unclear, partnerships must consider tax regulations such as Sections 61(a)(12), 731, and 752, among others, before restructuring. Likewise, partners should consider taxable income covered by cancellation of indebtedness income rules, where debt is repayed for less than the borrowed amount or reduced by consensus.

Debt

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Property contributions to partnerships more likely to result in gain after TRA `97

Article Abstract:

Section 351, a provision of the Taxpayer Relief Act of 1997 (TRA), may be disastrous. The 1997 Act requires a partner to make a tax-free contribution of property to a partnership. This applies even if such contribution is conducted by existing partners, upon development of the partnership, or upon the admission of an additional partner. Planned transfers of assets to partnerships as contributions to capital that have been historically taken as tax-free must be examined and possibly restructured.

Tax Law, Public Finance Activities, Laws, regulations and rules

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Troubled real estate partnerships: what options are available to foreign lenders?

Article Abstract:

There are several options open to foreign lenders that made a large number of loans to real estate partnerships that later went insolvent or bankrupt. These include debt restructuring and foreclosing on the collateral. However, before they decide on a course of action, these foreign lenders must first consider the US tax consequences of each option.

Foreclosure, Foreign banks

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