NYSBA: Report on Cancellation of Indebtedness and AHYDO Rules

The New York State Bar Association Tax Section has released a Report on the Cancellation of Indebtedness and AHYDO Rules of §§ 108(i) and 163(e)(5)(F) (No. 1182):

This Report provides recommendations for guidance under Sections 108(i) and 163(e)(5)(F), which were enacted as part of the American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5 (the “Stimulus Bill”). Sections 108(i) and 163(e)(5)(F) are designed (among other things) to help taxpayers who choose to reduce their outstanding debt by repurchasing the debt at a discount and taxpayers who need to modify (or otherwise restructure) the terms of their outstanding debt but wish to do so outside of bankruptcy.