Clifford Chance | The IRS Releases Temporary Regulations Regarding the Election to Defer Cancellation of Debt Income

31 August 2010

The IRS Releases Temporary Regulations Regarding the Election to Defer Cancellation of Debt Income

Banking & finance, Banking & securities regulation, Capital markets and structured debt, Debt capital markets, New York, Structured finance
Philip Wagman
Client Briefing

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The IRS Releases Temporary Regulations Regarding the Election to Defer Cancellation of Debt Income

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In August 2010, the IRS released a set of temporary regulations (the "Regulations") addressing the election to defer cancellation of indebtedness ("COD") income under Section 108(i) of the Internal Revenue Code ("Section 108(i)"). These Regulations clarify how Section 108(i) operates in a number of common situations.

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