This presentation covers:
- distressed debt – common transactions
- characterisation issues
- key income tax issues for the debtor:
- commercial debt forgiveness rules
- limited recourse debt rules
- key income tax issues for the creditor:
- loss on extinguishment of debt (bad debt, general deduction,capital loss)
- withholding tax
- TOFA
- key transactions:
- renegotiating debt repayments
- assignment of debt
- debt for equity swap.