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- Title
Real Estate & Passthrough Finance Techniques Corner.
- Authors
Rubin, Blake D.; Whiteway, Andrea Macintosh; Finkelstein, Jon G.
- Abstract
The article presents an analysis of liabilities when treated as recourse or nonrecourse for purposes of sale or exchange and cancellation of indebtedness (COD) income. The liability characterization under the Internal Revenue Code Sections 1001, 752, and 704(b) are explored. It also examines liability characterization in ten examples. It is concluded that a liability may be recourse for purposes of one provision of the Code but nonrecourse for purposes of another provision of the Code.
- Subjects
UNITED States; LIABILITIES (Accounting) -- Taxation; DEBT laws; NONRECOURSE debt; DEBT exchanges; TAXATION of debt cancellation; INTERNAL revenue law; UNITED States. Internal Revenue Code
- Publication
Journal of Passthrough Entities, 2010, Vol 13, Issue 4, p29
- ISSN
1099-7407
- Publication type
Article