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Determining a 'significant modification' under the final Cottage Savings Regulations

Article Abstract:

The aftermath of the final Internal Revenue Code Regulations issued by the IRS under Section 1001 in light of the Supreme Court's 'Cottage Savings Association' case is examined. The study fixates on the tax repercussions of the so-called significant modification of debt certificates on borrowers and holders. The final Regulations make it plain that partnership issuers reorganizing their obligation should outline accurately to evade deemed exchanges whenever plausible.

Tax Management, Methods, Management, Usage, Tax accounting, Tax administration and procedure, Tax administration, Tax planning, Debt financing (Corporations), Debt financing

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Taxation of many items affected by whether a joint venture has a trade or business

Article Abstract:

Take-in-kind joint ventures have an ambiguous status in federal income tax law, which leads to several income tax implications. Analysis of I.T. 3930 shows that a venture should not be considered to have a trade or business of its own if the ventures are authorized to independently market and acquire their share of the venture product.

Taxation, Joint ventures

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Distributive Share of Ordinary Income Was Not UBTI

Article Abstract:

The Internal Revenue Service ruled on whether or not distribution of ordinary income could be subject to unrelated business taxable income.

United States, Partnerships, Finance, taxation, & monetary policy, Internal Revenue Service, Laws, regulations and rules, Limited partnership, Limited partnerships, Tax exemption, Tax exemptions

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