500:
fair market value and the debt would be COD. (This intuitively makes sense because with recourse debt, any cancellation of the outstanding balance of the debt, after it has been satisfied to the extent of the FMV of the property given up, really is a termination of personal liability to pay that amount, unlike in a situation where the debt is nonrecourse). If the property has a value lower than its basis, then in the case of recourse debt you could get a capital loss and COD ordinary income on the same transaction, netting to the same dollar figure as with nonrecourse debt but potentially much worse for the taxpayer: The taxpayer would not only be burdened with ordinary rather than potentially capital gains, but may have more total income to report, offset only by a capital loss that would be unusable (except to a nominal extent in the case of individuals) if the taxpayer had no other capital transactions for the year. Only in the case of a taxpayer able to utilize one of the COD exclusions, such as insolvency, could this result be better.
458:, a corporation issued its own bonds as a dividend to its shareholders. When the bonds declined in value, Rail Joint repurchased them for less than their face amount. Ordinarily, retiring bonds for less than the issue price would result in taxable canceled debt. However, in holding that there was no COD for Rail Joint, the court noted that, unlike in a normal issuance of corporate debt for cash consideration, the original issuance of these bonds as dividends did not increase the capital of the corporation and did not create burdened assets to be later freed by the cancellation.
37:
289:
606:
political decision to subsidize farmers by offering a tax benefit. The student loan exclusion for those who do certain types of work is designed to maximize that benefit. Prior to the enactment of the Tax Cuts and Jobs Act of 2017, there were several lobbying efforts to amend 108(f)(1) for those who get total and permanent disability discharges, since under
827:. This act prohibited shareholders from increasing basis for their portions of the S corporation's excluded cancellation-of-debt income, for discharges of indebtedness after October 11, 2001. This effectively overturned the January 9, 2001, U.S. Supreme Court decision to allow such increases in basis in Gilitz v. Commissioner, 531 U.S. 206 (2001).
642:. Therefore, a cancellation of a $ 20,000 debt will not need to be reported as gross income. However, if a debt of $ 60,000 was cancelled, the taxpayer will have $ 10,000 in gross income because their total liabilities no longer exceed their total assets (cancelling $ 60,000 in debt means the taxpayer now has only $ 40,000 in liabilities).
520:. In order for this exception to apply, the amount of debt must actually be disputed. This can happen if the two parties actually have a good faith dispute over the amount owed. A written instrument containing the amount of debt will probably not satisfy this requirement. However, as the court decided in
495:
holds that in such a situation, the amount realized is the amount of the debt, and the fair market value of the property is irrelevant. That this difference between the adjusted basis of the property and the amount of the debt is simple gain rather than COD has potential upsides and downsides. On the
465:
doctrine, arguing that what really happens in these situations is a constructive dividend and purchase: The corporation constructively issues a cash dividend to shareholders, who then contribute that cash back to the corporation in exchange for the bonds; the burdened asset is thus the constructively
819:
So that the shareholders of an S corporation do not receive a tax benefit when individuals or other forms of business would not, when reducing tax attributes current year NOL is substituted by the shareholders' current year disallowed loss, and the NOL carryovers are substituted by the shareholders'
788:
If a taxpayer's tax attributes were not reduced, taxpayers could intentionally create large tax attributes by creating debt, cancelling the debt, and unjustly reducing their future taxes without paying on the debt. For example, a taxpayer could intentionally run up large amounts of business debt and
605:
The exclusions under
Section 108 are justified under various rationales. First, it is difficult to collect tax from insolvent taxpayers. The bankruptcy and the insolvency provisions defer the tax to a time when taxpayer is able to pay. The farm indebtedness provision, on the other hand, represents a
835:
A taxpayer may elect to apply the tax attribute reduction first against the basis of depreciable property of the taxpayer, not to exceed the aggregate adjusted bases of the depreciable property held by the taxpayer as of the beginning of the taxable year following the taxable year of the discharge.
815:
S corporations do not have net operating losses (NOL). Instead, the concept of NOL is handled at the shareholder level. Each shareholder must treat any loss or deduction that exceeds their stock and debt basis as a suspended (disallowed) loss, which carries forward indefinitely until applied toward
649:. The asset base for the insolvency exemption includes tax-advantaged retirement accounts, almost all types of which are excluded by law from the asset base in bankruptcy. The asset base for the insolvency exclusion also includes assets that serve as collateral for any debt carried by the taxpayer.
499:
If the same property had been burdened by recourse debt, and, as above, that property were foreclosed upon in full satisfaction of the debt, you would get a different result. The gain or loss would be determined with reference to the fair market value of the property, and the difference between the
487:
can have significant consequences if the debt is settled in foreclosure of the secured property. Generally, while the net gain or loss is the same regardless of the classification of the debt (it will always be the difference between the basis of the burdened property and the amount of the debt),
379:
Prior to this decision, the Court had already determined that the cancellation of debt was "a freeing of assets." Essentially, when debt is cancelled, money that would have been used to pay that debt is now free to be used on anything else the taxpayer wants. This is also known as "accession to
392:
A loan by itself is neither gross income to the borrower, nor a tax deduction to the lender. This is because there is "symmetry" of assets and liabilities on both side: the borrower's increased wealth when the loan is taken out is offset by an obligation to repay that same amount. Likewise, the
470:
is nonetheless good law, and has been expanded to encompass other situations where the taxpayer received nothing of value in exchange for the debt, such as when a guarantor of a loan who did not enjoy the benefit of the loan settles it for less than the face amount.
396:
When debt is cancelled, then that symmetry is destroyed. The borrower is now in a better position than if the loan was fully repaid. The taxpayer now has a greater ability to pay taxes and this is shown by including the amount of canceled debt in gross income.
393:
lender's loss of wealth by lending out that money is offset by the borrower's promise to pay back the entire amount. Ignoring interest, both sides will be in exactly the same position when the loan is repaid as they were in before the loan was even made.
417:
Failure to file Form 1099-C may subject the taxpayer to civil penalties, but such penalties are relatively minor, and rarely exceed $ 150.00 per form. There is no exemption from the filing requirement if canceled debt in excess of $ 600.00 is recognized.
437:
Generally, IRS Form 1099-C is to be filed along with reporting Form 1096 by the end of
January of the year following the date when the debt was canceled. However, if that date falls on a weekend, the filing date is postponed to the next business day.
1098:
784:
However, in the case of reducing the taxpayer's tax attributes, this policy does not create a new tax burden on the taxpayer. It instead reduces tax credits and carryforwards that would be used to offset future earned income.
730:, the taxpayer's tax attributes must be reduced, which is done through IRS Form 982 (Reduction of Tax Attributes Due to Discharge of Indebtedness). A taxpayer's tax attributes are, and must be reduced in the following order:
781:, that policy prevents creating a new tax burden on insolvent and bankrupt taxpayers, who are likely in a situation where they financially need that benefit, and who would likely be difficult or impossible to collect from.
413:
The creditor may be a lending institution, the subsequent holder of a note, a trustee for multiple owners of a single note or a governmental unit, but also includes individuals and business organizations of all kinds.
713:. If a reduction in price occurs after the parties have already reached an agreement, the Code treats the new agreed-upon price as if it were the original price, which means there will not be COD income to the buyer.
844:
If a separate bankruptcy estate was created, the trustee must reduce the bankruptcy estate's tax attributes by the cancelled debt. The taxpayer then "inherits" the ending tax attributes of the bankruptcy estate.
496:
one hand, the gain would be capital gain assuming the property foreclosed upon were a capital asset, unlike COD which is ordinary. On the other hand, COD is potentially excludable, as by insolvency (see below).
740:
General business credit – Any carryover to or from the taxable year of a discharge of an amount for purposes for determining the amount allowable as a credit under 26 U.S.C. §38 (relating to general business
638:
when their total liabilities exceed the fair market value of assets. For example, if a taxpayer has $ 100,000 in liabilities, but only $ 50,000 in assets, they are considered insolvent under the
491:
When property burdened by nonrecourse debt is foreclosed upon, there is no cancellation of indebtedness even if the amount of the loan exceeds the fair market value of the property. The case of
797:
The reductions in tax attributes are dollar-for-dollar to the amount of excluded COD income for the: NOL, capital loss carryover, and basis reduction. The reductions in tax attributes are 33
807:
cents-for-dollar of amount of excluded COD income for the: general business credit, maximum tax credit, passive activity loss and credit carryovers, and foreign tax credit carryovers.
744:
Minimum tax credit – The amount of the minimum tax credit available under 26 U.S.C. §53(b) as of the beginning of the tax year immediately following the taxable year of the discharge
429:. The IRS has issued a notice that lenders or servicers of loans discharged under these provisions are not required to issue Form 1099-C, and should not do so even voluntarily.
759:
Foreign tax credit carryovers – Any carryover to or from the taxable year of the discharge for purposes of determining the amount of the credit allowable under 26 U.S.C. §27
789:
losses, creating a large NOL. Then, after filing a bankruptcy to wipe out the debt, they could use the NOL carryforward for up to twenty years or until it was exhausted.
769:
When reducing general business credit or foreign tax credit carryovers, the reduction in tax attributes must be made in order that the carryovers are taken into account.
597:
If one of the two requirements are met, then the taxpayer must show that they fall under one of the five exclusions in order to avoid tax consequences on the COD Income.
349:
Billions of dollars of cancelled debts will generate many unexpected tax bills, due to debt cancellations that financial institutions have started accelerating in 2012.
686:
was either 1) incurred or assumed prior to
January 1, 1993, or 2) incurred or assumed to acquire, construct, reconstruct, or substantially improve the real property; and
410:
Generally, any creditor canceling debt of $ 600.00 or more is required to file Form 1099-C by
January 31 of the next year following the date when the debt was canceled.
701:
Sometimes a price agreement will be reached between buyer and seller, but for some reason both agree to reduce that price at a later date. A strict reading of the
664:
50% or more of the aggregate gross receipts of the taxpayer for the three taxable years preceding the discharge is attributable to the trade or business of farming
1025:
766:
When reducing NOL or capital loss carryovers, the reduction in tax attributes must be in the order of the taxable years that each carryover was created in.
671:
There are additional rules as well regarding the total amount excludable, which cannot exceed the sum of tax attributes and business and investment assets.
756:
Passive activity loss and credit carryovers – Any passive activity loss or credit carryover under 26 U.S.C. §469(b) from the taxable year of the discharge
610:
rules, such borrowers are subject to a three-year post-discharge review period during which their incomes from employment cannot exceed the poverty line.
594:
For example, if the lender cannot legally enforce the debt, then the taxpayer is not liable for that debt and will therefore not have tax consequences.
1099:"King, Portman, Coons Urge Administration to Immediately Discharge Outstanding Loans for Families Suffering from Child's Death or Permanent Disability"
346:. There are exceptions to this rule, however, so a careful examination of one's COD income is important to determine any potential tax consequences.
705:
says that the amount reduced is COD income, it does not fall under one of the four exclusions, and is thus gross income. To remedy this situation,
943:
161:
824:
911:
Samuel A. Donaldson, Federal Income
Taxation of Individuals: Cases, Problems and Materials, 2nd Edition (St. Paul: Thomson/West, 2007), 113.
683:
was incurred or assumed by the taxpayer in connection with real property used in a trade or business and is secured by such real property;
1076:
376:
The Court defined income as 1) accession to wealth; 2) that is clearly realized; and 3) over which the taxpayer has complete dominion.
1240:
Publication 4681: Canceled Debts, Foreclosures, Repossessions, and
Abandonments (for Individuals) – For Use in Preparing 2012 Returns
562:
that has been discharged due to the death or total permanent disability of the borrower. This particular provision was added in the
118:
508:
The
Disputed Debt Doctrine (also known as the Contested Liability Doctrine), is yet another exception to including COD income in
1464:
58:
46:
1174:
820:
disallowed loss carryovers. The tests for exclusion of cancellation-of-debt income still happen at the S corporation level.
607:
317:
275:
198:
763:
The reduction in tax attributes is made after the determination of the tax imposed for the taxable year of the discharge.
193:
148:
93:
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63:
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83:
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88:
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68:
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454:
Whether or not there is cancellation-of-indebtedness income can sometimes be ambiguous and controversial. In
426:
183:
78:
28:
661:
such indebtedness was incurred directly in connection with the taxpayer's trade or business in farming; and
235:
113:
367:
969:"Notice 2022-1: Instructions for Lenders and Loan Servicers Regarding Certain Discharged Student Loans"
250:
123:
710:
693:
However, this exclusion will only reduce the basis of the depreciable real property of the taxpayer.
425:
has been discharged due to the death or permanent disability of the borrower under provisions of the
310:
98:
133:
128:
53:
668:
However, such a taxpayer must be a "qualified person" as defined in 26 U.S.C. § 49(a)(1)(D)(iv)
583:
In order to qualify under these exclusions, the taxpayer's indebtedness must result from either
706:
20:
1186:
702:
645:
The criteria for the insolvency exclusion are considerably more strict than those used under
639:
492:
339:
103:
921:
1102:
303:
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230:
1175:
http://www.pebforum.com/transition-issues/12662-student-loan-repayment-program-issues.html
8:
260:
750:
Capital loss carryover – Any capital loss carryover to the taxable year of the discharge
1469:
619:
225:
36:
574:
Student loans forgiven for working for certain classes of employers are also excluded
524:, the Disputed Debt Doctrine can also apply if the debt is not legally enforceable.
484:
168:
270:
255:
968:
555:
If the indebtedness discharged is qualified real property business indebtedness
1458:
992:
480:
331:
138:
108:
1232:
1187:"Total and Permanent Disability Discharge: Post-Discharge Monitoring Period"
870:
USA Today page A1 published March 5, 2012 "Old debt could lead to tax bills"
747:
Net capital loss – Any net capital loss of the taxable year of the discharge
334:
may have tax consequences when debt is cancelled. This is commonly known as
778:
727:
533:
509:
343:
1012:
570:
In addition, the Code recognizes a
Purchase Price Adjustment exception.
1105:
734:
Net operating loss (NOL) – Any NOL of the taxable year of the discharge
211:
737:
NOL carryover – Any NOL carryover to the taxable year of the discharge
679:
A qualified real property business indebtedness is indebtedness which
635:
547:
566:, and applies to discharges during calendar years 2018 through 2025.
540:
If the discharge of indebtedness occurs in a Title 11 case—i.e., a
245:
1077:"Discharged Student Loan Debt No Longer Taxable Under New Tax Law"
1013:"Publication 17: Tax guide 2022 for individuals (Cat. No. 10311G)"
342:, the discharge of indebtedness must be included in a taxpayer's
265:
240:
188:
772:
674:
384:, it seems only natural to include COD income in gross income.
363:
600:
552:
If the indebtedness discharged is qualified farm indebtedness
546:
If the discharge of indebtedness occurs when the taxpayer is
400:
753:
Basis reduction – The basis of the property of the taxpayer
944:"Bank Cannot Issue 1099-C And Subsequently Try To Collect"
810:
421:
One exception to the requirement to file 1099-C is when a
823:
Furthermore, on March 9, 2002, President Bush signed the
590:
indebtedness subject to which the taxpayer holds property
839:
816:
future earned income pass through by the S corporation.
792:
618:
A Title 11 case is one that falls under Title 11 of the
1242:. Internal Revenue Service. January 15, 2013. p. 5
432:
352:
1227:
1225:
830:
587:indebtedness for which the taxpayer is liable; or
1456:
709:passed 26 U.S.C. § 108(e)(5), also known as the
405:
1222:
1015:(PDF). Irs.gov, 67. Retrieved 14 February 2023.
1125:
1123:
825:Job Creation and Worker Assistance Act of 2002
716:
657:A taxpayer has qualified farm indebtedness if
652:
974:. Internal Revenue Service. December 21, 2021
773:Policy reasons behind reducing tax attributes
675:Qualified real business property indebtedness
311:
696:
488:there are potentially huge tax differences.
1189:. Texas Guaranteed Student Loan Corporation
1120:
689:the taxpayer elects to apply this exception
601:Policy reasons behind COD income exclusions
461:The IRS has formally non-acquiesced to the
1448:IRS Publication 908 (Bankruptcy Tax Guide)
401:IRS Form 1099-C and reporting requirements
318:
304:
1026:"Taxation of Cancellation of Debt Income"
777:In the case of excluding COD income from
503:
441:
1079:. Special Needs Answers. 4 January 2018
811:NOL special treatment for S corporation
532:Not all COD income must be included in
1457:
446:
357:
840:In case of separate bankruptcy estate
793:Amount of reduction of tax attributes
558:If the indebtedness discharged is a
922:"Form 1099-C, Cancellation of Debt"
474:
13:
512:. This doctrine can be found in a
433:When one must file IRS Form 1099-C
373:Commissioner v. Glenshaw Glass Co.
14:
1481:
336:cancellation-of-debt (COD) income
220:Automated payment transaction tax
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536:. There are several exceptions:
353:Policy reasons behind COD income
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84:Generation-skipping transfer tax
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726:If COD income is excluded from
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1165:, 916 F.2d 100 (3rd Cir. 1990)
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831:Election to reduce basis first
514:Third Circuit Court of Appeals
456:Commissioner v. Rail Joint Co.
99:Internal Revenue Service (IRS)
1:
1465:Taxation in the United States
629:
564:Tax Cuts and Jobs Act of 2017
527:
427:Tax Cuts and Jobs Act of 2017
406:Who must file IRS Form 1099-C
184:State and local tax deduction
29:Taxation in the United States
1046:916 F.2d 110 (3rd Cir. 1990)
236:Efficient Taxation of Income
7:
1101:(Press release). Office of
1003:61 F.2d 751 (2nd Cir. 1932)
717:Reduction in tax attributes
653:Qualified farm indebtedness
387:
380:wealth." Therefore, under
368:United States Supreme Court
362:The standard definition of
104:Internal Revenue Code (IRC)
10:
1486:
721:
1163:See Zarin v. Commissioner
711:purchase price adjustment
697:Purchase price adjustment
900:U.S. v. Kirby Lumber Co.
848:
479:Whether secured debt is
294:United States portal
162:State and local taxation
124:Constitutional authority
19:This article is part of
608:Department of Education
54:Alternative minimum tax
1028:. schuhgoldberglaw.com
504:Disputed Debt Doctrine
251:Hall–Rabushka flat tax
1320:26 U.S.C. § 108(b)(1)
1207:26 U.S.C. § 108(d)(2)
1141:26 U.S.C. § 108(f)(1)
1066:26 U.S.C. § 108(a)(1)
861:26 U.S.C. § 61(a)(12)
703:Internal Revenue Code
640:Internal Revenue Code
518:Zarin v. Commissioner
493:Commissioner v. Tufts
466:re-contributed cash.
442:Special circumstances
340:Internal Revenue Code
276:Border-adjustment tax
231:Competitive Tax Plan
1108:. February 28, 2018
902:, 284 U.S. 1 (1931)
879:348 U.S. 426 (1955)
358:Accession to wealth
338:. According to the
261:Taxpayer Choice Act
620:United States Code
212:Federal tax reform
330:Taxpayers in the
328:
327:
129:Taxpayer standing
59:Capital gains tax
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475:Nonrecourse debt
320:
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199:State tax levels
169:State income tax
114:Revenue by state
47:Federal taxation
39:
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15:
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1299:§ 108(c)(3)–(4)
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5:
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1427:§ 108(d)(7)(A)
1417:
1415:§ 108(d)(7)(B)
1405:
1393:
1382:
1370:
1368:§ 108(b)(4)(C)
1358:
1356:§ 108(b)(4)(B)
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1344:§ 108(b)(4)(A)
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647:bankruptcy law
634:A taxpayer is
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382:Glenshaw Glass
370:case entitled
366:is found in a
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326:
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1239:
1233:"Insolvency"
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1191:. Retrieved
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953:December 14,
951:. Retrieved
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728:gross income
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579:Requirements
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534:gross income
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174:Property tax
1439:§ 108(b)(5)
1380:§ 108(b)(3)
1332:§ 108(b)(2)
1311:§ 108(c)(1)
1287:§ 108(g)(3)
1275:§ 108(g)(1)
1263:§ 108(g)(2)
1219:§ 108(d)(3)
1153:§ 108(d)(1)
1132:§ 108(e)(5)
1032:14 December
978:January 14,
928:14 December
485:nonrecourse
94:Payroll tax
1459:Categories
1106:Angus King
948:Forbes.com
630:Insolvency
624:bankruptcy
542:bankruptcy
528:Exclusions
468:Rail Joint
463:Rail Joint
448:Rail Joint
149:Resistance
89:Income tax
74:Excise tax
69:Estate tax
1470:Tax terms
1403:§ 1366(d)
1112:April 18,
1083:April 17,
924:. Irs.gov
636:insolvent
548:insolvent
179:Sales tax
707:Congress
481:recourse
450:doctrine
388:Symmetry
246:Flat tax
79:Gift tax
21:a series
1246:May 15,
1103:Senator
802:⁄
741:credit)
722:General
266:USA Tax
241:FairTax
189:Use tax
144:Evasion
139:Protest
119:History
1193:May 5,
516:case,
364:income
1236:(PDF)
972:(PDF)
849:Notes
522:Zarin
226:9–9–9
134:Court
1248:2013
1195:2013
1114:2018
1085:2018
1034:2013
980:2022
955:2013
930:2013
1437:Id.
1425:Id.
1413:Id.
1401:Id.
1390:Id.
1378:Id.
1366:Id.
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1297:Id.
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1273:Id.
1261:Id.
1217:Id.
1151:Id.
1130:Id.
1056:Id.
889:Id.
626:).
483:or
1461::
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1224:^
1122:^
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1197:.
1116:.
1087:.
1036:.
982:.
957:.
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804:3
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312:t
305:v
Text is available under the Creative Commons Attribution-ShareAlike License. Additional terms may apply.
