Debt discharge income and S corporations: An analysis after the tax court decision in Winn.

SelectedWorks Author Profiles:

James A. Fellows

Document Type

Article

Publication Date

1998

Date Issued

January 1998

Date Available

December 2013

ISSN

0040-0181

Abstract

Excerpt: “How do the debt discharge rules work if the taxpayer is an S corporation…? Does the debt discharge income flow through separately to the shareholder? If so, then whether or not the income is taxable depends on whether the individual shareholder is insolvent, and not the corporation itself. Or is the question of insolvency determined at the corporate level? If that is the case, then how is the corresponding reduction of tax attributes handled? Another significant issue is the effect of the debt discharge exclusion on the tax basis of the shareholder’s stock…These are some of the issues that we discuss in this article…” p.46

Comments

Excerpt only. Full-text article is available through licensed access provided by the publisher. Published in Taxes, 76(2), 46-59.

Language

en_US

Publisher

CCH Inc.

Creative Commons License

Creative Commons License
This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License.

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