As part of the American Recovery and Reinvestment Act of 2009, a new section, IRC Sec. 108(i), provides certain taxpayers an election to defer cancellation of indebtedness income for a period of five years. Generally, a discharge of indebtedness results in income to the debtor equal to the difference between the debt instrument's adjusted issue price and the price at which the debt is satisfied. Proposed regulations allow modified valuation of transferred partnership interest in a debt-for-equity exchange.
Click here to access our sample discussion of IRC Sec. 108(i) and proposed regulations relevant to partnership interest transfers.
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