Learn the core principles of CODI, its tax implications, and unique considerations for corporations, partnerships, and S corporations in distress.
Understanding the tax implications of financial distress is a critical yet complex aspect of advising corporations, partnerships, and S corporations. This live webinar offers a high-level overview of this challenging area, focusing on key topics like debt forgiveness, bankruptcy and insolvency exclusions, and the impact of tax attribute reduction.
While this session won’t delve into every technical detail, it will provide a clear summary of the foundational principles, equipping attendees with the knowledge to navigate these issues more confidently. Ideal for legal, tax, and financial professionals, this webinar provides a unique opportunity to gain practical insights, ask questions in real time, and walk away with a solid starting point for addressing these intricate tax challenges.
Learning Objectives
- You will be able to discuss the tax challenges for financially distressed entities.
- You will be able to define CODI and its general tax implications.
- You will be able to explain unique considerations for partnerships.
- You will be able to identify key tax issues for S Corporations.
Agenda
Introduction and Overview
Cancellation of Debt Income (CODI): Core Principles
- What Is CODI?
- Considerations
- Exclusions Under IRC §108
- Impact on Tax Attributes
Corporations in Financial Distress
- CODI Treatment for Corporations
- Tax Implications of Asset Sales
- Liquidation Considerations
- Section 382 Limitations
Partnerships: Unique Considerations
- Pass-Through Nature of CODI
- Debt and Basis Adjustments
- Loss Allocations
S Corporations: Key Tax Issues
- Pass-Through CODI Treatment
- Debt Basis and Forgiveness
- Distributions During Liquidation
Shared Considerations Across Entity Types
- Tax Attribute Reductions
- Tax Planning Strategies
- Compliance Obligations
Practical Applications and Real-World Examples
Closing Remarks and Resources