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Tax Law Roundup current law developments in U.S. taxation

Tag Archives: 7704

New IRS Safe Harbor on When COD Is Qualifying Income for Publicly Traded Partnerships

Posted on By Steven R. Schneider Posted in Cancellation of Debt Income, Partnership/LLC, Passthrough Entity

The IRS issued Rev. Proc. 2012-28, providing a helpful safe harbor for publicly traded partnerships (PTPs) to avoid non-qualifying PTP income from debt cancellation.  Prior to this guidance, PTPs did not have clear guidance on whether Cancellation Of Debt (COD) income was qualifying income for PTP qualification purposes.  PTPs need minimum amounts of qualifying income… Continue Reading