The Resource U.S. taxation of income from the retirement of nonfunctional debt

U.S. taxation of income from the retirement of nonfunctional debt

Label
U.S. taxation of income from the retirement of nonfunctional debt
Title
U.S. taxation of income from the retirement of nonfunctional debt
Creator
Subject
Summary
This article considers the tax consequences of a debt- equity swap, in relation to the possible currency gain acquired when cancellation of indebtedness income is received by the shareholder of an insolvent foreign corporation. The author refers to the common law of the taxation of exchange gains and losses, emphasizes the character and the timing of the realization of exchange gain or loss, explains section 988 and the implementing regulations that prescribe the rules for taxing exchange gain resulting from a debt-equity swap and considers the debt-equity swap's effect on the shareholder of an insolvent foreign corporation by considering whether gain from a debt-equity swap is currently includible in income
Citation source
In: Tax Notes International. - Arlington. - (1993),
http://library.link/vocab/creatorName
Toussaint, Tyson
Language note
English
http://library.link/vocab/subjectName
debt-equity swap
Label
U.S. taxation of income from the retirement of nonfunctional debt
Instantiates
Publication
Abbreviated title
TaxNint
Label
U.S. taxation of income from the retirement of nonfunctional debt
Publication
Abbreviated title
TaxNint

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