Internal Revenue Bulletin:  2013-30 

July 22, 2013 

INCOME TAX


Table of Contents

T.D. 9622 T.D. 9622

Final regulations under section 108(i) provide guidance to C corporations regarding the accelerated inclusion of deferred COD income and accelerated deduction of deferred OID, including special rules for members of consolidated groups. In addition, these regulations provide rules applicable to all taxpayers regarding deferred OID deductions under section 108(i)(2).

T.D. 9623 T.D. 9623

Final regulations under section 108(i) of the Code provide rules regarding partnerships and S corporations. Section 108(i) allows a taxpayer to defer discharge of indebtedness income (and in certain cases, deductions for original issue discount) arising from a reacquisition of an applicable debt instrument that occurs in 2009 or 2010 for a four or five taxable-year period (unless an acceleration event occurs earlier). Once the deferral period ends, taxpayers take into account the deferred income and deductions ratably over a five taxable-year period.


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