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- Title
TAX AND CROSS-COLLATERALIZED NONRECOURSE LIABILITY.
- Authors
Kahn, Douglas A.; Kahn, Jeffrey H.
- Abstract
This Article explores the tax treatment of cross-collateral nonrecourse debt. When using the term cross-collateral debt, we are referring to nonrecourse debt that is connected with more than one piece of property. While tax issues concerning cross-collateralized properties can arise in several circumstances, the focus of this Article is on the tax treatment of a transfer of property subject to a cross-collateralized nonrecourse liability to a controlled corporation in exchange for stock that qualifies for some or all nonrecognition under § 351. The Article also discusses two other tax issues involving cross-collateralized nonrecourse liability--namely, cancellation of debt and determination of basis issues.
- Subjects
NONRECOURSE debt; DEBT; CORPORATIONS; DEBT cancellation; DEBT management
- Publication
Florida Tax Review, 2021, Vol 24, Issue 2, p626
- ISSN
1066-3487
- Publication type
Article
- DOI
10.5744/ftr.2021.2005