Taxation

IRS Ruling Limits Exclusion to COD Income

, New York Law Journal

   | 0 Comments

In their Taxation column, Ezra Dyckman and Daniel Stahl write: While cancellation of indebtedness generally results in ordinary income for the debtor (COD income), the Internal Revenue Code provides for several exceptions under which COD income can be excluded. Of particular importance for owners of real estate is Section 108(c), under which a taxpayer can elect to exclude COD income that results from the discharge of "qualified real property business indebtedness" under certain circumstances. The IRS recently interpreted one of the requirements for debt to constitute QRPBI in a manner that will cause debt secured by condominium units held for sale to fail to qualify.

This premium content is reserved for New York Law Journal subscribers.

Continue reading by getting started with a subscription.

Already a subscriber? Log in now

What's being said

Comments are not moderated. To report offensive comments, click here.

Preparing comment abuse report for Article #1202784537098

Thank you!

This article's comments will be reviewed.