Todd B. Reinstein
A common fact pattern for many start-up companies
is to issue multiple rounds of convertible preferred stock to venture
capitalists to develop new products until a stream of revenue can be
developed. This leaves these companies with a large net operating loss
The Tennessee Department of Revenue ("the Department") recently published Letter Ruling #11-44 ("the Ruling"), which addressed many issues related to potential income or gain that may arise from the discharge of indebtedness ("COD"), as well as the ancillary effects on other...