By Grant W. Newton
The hundreds of thousands of mergers, acquisitions, and start-ups that experience characterised the earlier ten years of commercial have created increasingly more firms in monetary difficulty: particularly, a scarcity a bet capital or fast money. for this reason, financial ruin security is now seen as a strategic movement to guard businesses from their collectors and make allowance them to reorganize. financial ruin and Insolvency Taxation, 3rd variation offers the solutions to the questions monetary managers may have at the tax elements of the "bankruptcy strategy."
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Extra resources for Bankruptcy & insolvency taxation
C. sections 332, 351, 368, 721, and 731. The preamble also provides: In general, if assets are transferred in a tax-free transaction and the transferee receives the assets with a carryover (or, in certain cases, a substituted) basis, any built-in income or gain is taxed when the transferee disposes of the asset. If, however, the debtor acquires its own indebtedness, the indebtedness is extinguished. In that case, the indebtedness in all cases should be treated as if it is acquired by the transferee and then satisfied.
Section 108(e)(6). 3(a)(iv). The opposite scenario is addressed here— the shareholder’s cancellation or satisfaction of a corporation’s obligation. 79 Unlike the stock-for-debt exception 73 Treas. Reg. 108-2(c)(4)(i). Treas. Reg. 108-2(c)(4)(v). 75 Treas. Reg. 108-2(f). 76 See Rev. Rul. B. C. section 108(e)(4)). 77 See Treas. Reg. 108-2(e). 9(a). 13 regarding the cancellation of a subsidiary’s debt by its parent corporation in the consolidated group context. C. 4(c), the capital-contribution situation generally involves a creditor who is an existing shareholder of the debtor corporation.
C. section 108(e)(4) apply. Similarly, if S had outstanding debt held by unrelated parties, the acquisition by P of the S debt in anticipation of P’s buying the S stock is also an indirect acquisition. ” A holder of the debt is treated as having acquired that debt in anticipation of becoming related if the relationship is established within 6 months after the debt is acquired. This appears to be a conclusive presumption. If the relationship is not established within 6 months, “all facts and circumstances will be considered .
Bankruptcy & insolvency taxation by Grant W. Newton