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IRS Issues Guidance on Loan Modifications

IRS Guidance on Distressed Debt Investments by REITs: IRS Issues Guidance on Application of Income & Asset Tests for REIT Qualification to Modifications of Debt Held by REITs and to Purchases of Distressed Debt by REITs. Sullivan & Cromwell LLP – January 6, 2011. Download. On January 5, 2011, the IRS issued Rev. Proc.

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The adjusted issue price typically is the principal amount if the following is true: 1. The debt was not issued at a discount. 2. The debt provided for current interest pay-ments at a fixed or variable rate. Gain or loss to the creditor is measured by the difference between (1) the new debt issue price and (2) the old debt tax basis.

On November 14, 2018, the IRS published new proposed regulations relating to hardship distributions from 401(k) plans and 403(b) plans. The proposed regulations primarily respond to issues raised by changes to hardship distributions in the Bipartisan Budget Act of 2018 ("BBA) and the Tax Cuts and Jobs Act of 2017 (TCJA).

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In the midst of a struggling economy, firms understand the importance of finding and retaining top talent. To recruit and preserve such valuable resources, numerous firms have turned to offering traditional and compensation-related employee loans. Whether such loans are constructed for retention or to administer employee aid, their tax treatment should be closely

Unless Congress agrees to a retroactive extension, large numbers of owners could face big tax bills following short sales, foreclosures or loan modifications next year when lenders cancel a portion of.

IRS issues final electronic Media Rules WHO’S AFFECTED This guidance applies to qualified defined benefit and defined contribution plans, including multiemployer plans and 403(b) arrangements, and governmental section 457(b) plans. It does not apply to nonqualified deferred.

The guidance from the IRS dovetails with January clarification from the Securities and Exchange Commission that suggested fast-tracking loan modifications would not jeopardize the so-called QSPE.

How to properly close a Loan Modification Contents Car chastises lenders Banking committee chairman chris dodd 25 billion lawsuit Committee chair annette nellen Transaction Focused Issues – Bad Debts Under 166 irs guidance does not define "charge off" Taxpayer must take action to remove the worthless portion of an asset from its books as an indication of worthlessness Courts have held thatRead More

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