Download Bankruptcy & insolvency taxation by Grant W. Newton PDF

By Grant W. Newton

The millions of mergers, acquisitions, and start-ups that experience characterised the earlier ten years of commercial have created increasingly more businesses in monetary hassle: particularly, a scarcity a big gamble capital or speedy funds. therefore, financial disaster security is now considered as a strategic circulate to guard agencies from their collectors and make allowance them to reorganize. financial disaster and Insolvency Taxation, 3rd version offers the solutions to the questions monetary managers can have at the tax elements of the "bankruptcy strategy."

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2d 751 (2d Cir. 1932) and Fashion Park, Inc. v. C. 600 (1954). C. at 813. Case law addresses this concept in other situations. See Bradford v. 2d 935 (6th Cir. 1956); Eagle Asbestos & Packing Co. v. 2d 528 (Ct. Cl. 1965); Yale Avenue Corp. v. C. 1062 (1972). 44 Preslar v. 3d 1323, 1327 (10th Cir. 1999). , Private Letter Ruling 200243034 (July 26, 2002) (no DOI income from the discharge of unliquidated tort and environmental claims). 2d 110 (3d Cir. C. 1084 (1989). 46 See also Vanguard Recording Society v.

V. 24 Both cases involved fact patterns that are similar to the following scenario. Assume that a corporation issued preferred stock for $100 and the value of the preferred stock increases in value to $165. The corporation redeems the preferred stock with $165 in debt. The corporation later repurchases the debt for $120. Fashion Park, a 1954 decision, preceded any regulation on DOI income from the repurchase of debt. Based on Kirby Lumber and Rail Joint Co. v. S. 1 (1931). Although calculation of the adjusted issue price is the more controversial part of this equation, sometimes the valuation of the repurchase price is at issue.

P surrenders the debt to S in exchange for newly issued S stock equal in value to the fair market value of the debt. Even though P is the sole shareholder of S both before and after, the IRS allowed the form to control and applied the stock-for-debt rules and not the capital-contribution rules. As a result, income to S is measured by the excess of the principal amount of the debt over the value of the stock issued, and not by the principal amount of the debt over P’s basis in the debt. Assuming the adjusted issue price of the debt and the value of the S stock are equal, S would not have DOI income.

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