Internal Revenue Bulletin: 2012-24
June 11, 2012
Income from discharge of indebtedness. This ruling amplifies Revenue Ruling 92-53, 1992-2 C.B. 48, by describing how discharged partnership excess nonrecourse debt is taken into account in measuring the insolvency of the partners under section 108(d)(3) of the Code. The ruling provides that to the extent discharged excess nonrecourse debt generates cancellation of indebtedness (COD) income that is allocated under section 704(b) (and the regulations thereunder), each partner treats its portion of the discharged excess nonrecourse debt related to such COD income as a liability in measuring insolvency under section 108(d)(3). Rev. Rul. 92-53 amplified.
Final regulations under section 36B of the Code relate to the premium tax credit, enacted by section 1401 of the Affordable Care Act.
This notice extends interim guidance under section 833 of the Code provided in Notice 2010-79 and Notice 2011-51 on the modification of section 833 treatment of certain health organizations. Notice 2011-51 modified and superseded.
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