Aprill: Legislation Needed to Exclude All Student Loan Forgiveness From Income

On Friday, I blogged the IRS's issuance of Rev. Rul. 2008-34, which clarifies that law school public interest loan forgiveness programs qualify for the § 108(f) exception (and, as a result, students need not report the forgiven interest as discharge of indebtedness income).  Ellen Aprill (Loyola-L.A.) cautions that "because the tax-free status of loan forgiveness under § 108(f) pursuant to the College Cost Reduction and Access Act of 2007 may be available for some borrowers, uncertain for others, and unavailable for yet others, supporters of this recent legislation have identified the need for and are seeking legislation extending § 108(f)."  See Philip G. Schrag (Georgetown), Federal Studet Loan Repayment Assistancce for Public Interest Laywers and Other Employees of Governments and Nonnprofit Organizations, 36 Hofstra L. Rev. 27 (2007).