Section 108 I

108 i generally provides relief to corporate and certain other business taxpayers by giving them an option to irrevocably elect to defer recognition of cancellation of debt cod income resulting from a reacquisition of applicable debt instruments in tax years 2009 and.

Section 108 i. Section 108 1 when applications are required. The time for making a section 108 i election has passed. Application for a permit shall be made to the building official and a permit shall be obtained prior to the commencement of any of the following activities except that applications for emergency construction alterations or equipment replacement shall be submitted by the end of the first working.

Thus a s deferred section 752 amount with respect to debt one and debt two equals 200 the lesser of a s aggregate deferred amounts with respect to debt one and debt two of 250 or gain that a would. If you made an election under section 108 i to defer income from the discharge of business debt arising from the reacquisition of a debt instrument in 2009 or 2010 don t report the amount deferred under the election in lines 1a through 1d and line 2. The section 108 loan guarantee program section 108 provides communities with a source of low cost long term financing for economic and community development projects.

Enacted in 2009 the american recovery and reinvestment act p l. Codi under section 108 a cont d bankruptcy insolvency qualified principal residence indebtedness added by mortgage forgiveness debt relief act of 2007 for debt cancelled before january 1 2013. Insolvency exclusion exclusion only applies to the extent of.

108 i to the internal revenue code. Section 108 i permits a debtor to defer the recognition of cod income from the purchase exchange or forgiveness of a debt instrument of the debtor as well as a contribution to the capital of. Section 1951 b 2 b of pub.

In the case of any discharge of indebtedness to which subparagraph a or b of section 108 a 1 of the internal revenue code of 1986 formerly i r c. Ii under paragraph b 3 ii of this section the amount of gain that a would recognize under section 731 as a result of the reacquisitions absent the section 108 i 6 deferral is 200. 31 2008 and before jan.

If any discharge cancellation or modification of indebtedness of a railroad corporation occurs in a taxable year beginning after december 31 1976 pursuant to an order of a court in a proceeding referred to in section 108 b a or b which commenced before january 1 1960 then. It is no longer available. To the extent section 108 e 5 applies the basis of the acquired property is reduced by the amount of the cod 16 section 108 i was a cod income tax deferral benefit available for cancellation reacquisition or modification of a business debt occurring after dec.