Tax Notes has published Daniel I. Alvarado's, CPA, letter to the IRS regarding Proposed Regulation 154159-09. Mr. Alvarado's letter points out that proposed regulations (REG-154159-09) on discharge of indebtedness income of a grantor trust do not address whether the fair market value of assets and liabilities owned by the grantor trust are directly attributed to the owner for purposes of section 108(d)(3).
See "CPA Expresses Concerns With Prop Regs On Discharge Of Indebtedness Income," TNT 126-25, June 15, 2011.
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.
See "CPA Expresses Concerns With Prop Regs On Discharge Of Indebtedness Income," TNT 126-25, June 15, 2011.
Posted by Brian Spring, Associate Editor, Wealth Strategies Journal.

Leave a comment