Sect. 108 and Cancellation of Debt Income: Navigating IRS Rules
Deferring Tax Under This Complex Code Section and Under Latest Guidance
Recording of a 110-minute CPE/CLE webinar with Q&A
This teleconference will provide tax advisors and compliance professionals with an in-depth briefing on Sect. 108 and the most recent and highly relevant regulatory changes, guidance and rulings affecting COD income.
- Sect. 108 overview
- Different impacts on different business structures
- Types of debts that can be canceled
- Implications for income exclusion, credits, NOLs, passive loss carryovers, OID discounts
- Review of classification of COD income from workouts under Sect. 108(i)
- Deferred benefit for reacquired debt instruments
- Situations in which it may be more prudent not to defer
- Rev. Proc. 2009-37
- Election procedures and partial elections
- Debt-by-debt elections
- Temporary regs, November 2010 (T.D. 9497)
- For C corporations:
- Acceleration of deferred COD income
- Acceleration of deferred OID deductions
- Calculations of earnings and profits under a Sect. 108(i) election
- For C corporations:
- Other material IRS interpretive guidance and rulings
- Outlook for future guidance
- Tax planning and compliance considerations
- Best practices for documenting election procedures
- Timing of cancellation of indebtedness
- Including COD income in federal returns
The panel will explore these and other important areas:
- How Sect. 108 generally affects C corporations, partnerships, LLCs and S corporations.
- The aspects of Sect. 108(i) and Rev. Proc. 2009-37 that continue to demand taxpayers' attention.
- The ramifications of the temporary regs on accelerating deferred COD income and OID deductions, and calculating earnings and profits under Sect. 108(i) election.
- The IRS guidance documents and rulings in the area of Sect. 108 that require particular attention.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Kaufman Gilpin McKenzie Thomas Weiss
He works with business clients on tax strategies at all stages of the company life cycle and in a broad range of... | Read More
He works with business clients on tax strategies at all stages of the company life cycle and in a broad range of transactions, including choice of entity, joint ventures, M&A and reorganizations. He is a frequent speaker on business tax planning topics.Close
Capell Barnett Matalon & Schoenfeld
His practice encompasses business and tax planning, estate planning and federal and state tax dispute resolution,... | Read More
His practice encompasses business and tax planning, estate planning and federal and state tax dispute resolution, among other engagements. He is a frequent writer on tax topics, including articles on Sect. 1031 like-kind exchanges, for professional journals.Close
Mr. Strasbaugh is the Practice Leader of Ballard Spahr's Tax Group. His client work delves into preserving NOLs... | Read More
Mr. Strasbaugh is the Practice Leader of Ballard Spahr's Tax Group. His client work delves into preserving NOLs and other tax benefits in workouts under sections 108 and 382, and cross-border acquisitions using disregarded and hybrid entities, among others. He also provides tax advice concerning domestic M&A, tax-sharing agreements among members of consolidated return groups, executive compensation issues, and numerous other matters.Close
As part of the firm's Tax Practice Group, she works with large corporate clients on matters such as structuring tax... | Read More
As part of the firm's Tax Practice Group, she works with large corporate clients on matters such as structuring tax aspects of transactions, determining availability of net operating losses and assessing tax shelter reporting obligations, among others. She is a frequent writer and speaker on how new tax rules affect corporations' tax positions and reporting obligations.Close