Debt discharge income and S corporations: an analysis after the Tax Court decision in Winn

Article Abstract:

The Tax Court in 1997's Winn v. Commissioner effectively overruled several IRS rulings by allowing IRC Subchapter S corporation stockholders to use discharge of indebtedness income to proportionately increase their stock bases. The court found that the S corporation's section 108 excludable amount was an item of income. The decision can be the basis of analyses of similar issues.

Extinguishment of debts, Debt cancellation

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Converting to a limited liability company: the issue of debt allocation to the LLC members

Article Abstract:

The authors discuss the federal tax consequences of converting to a limited liability company from a partnership or corporation, including the handling of debt allocation.

Limited liability companies, Allocation (Taxation), Tax allocation

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Tax basis and shareholder guarantees of S corporation debt: the economic outlay doctrine revisited

Article Abstract:

The authors discuss the economic outlay doctrine and its application to S corporation stockholders attempting to obtain basis in corporate debt.

Finance, Stockholders, S corporations, Loss deductions, Loans, Basis (Taxation)

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