Section 108

1954 relating to exclusion from gross income as amended by section 2 applies and which occurs before january 1 1982 or which occurs in a proceeding in a bankruptcy case or similar.

Section 108. Ii under section 61 a 12 section 108 e 4 and paragraphs and of this section s realizes 1 000 000 of income from discharge of indebtedness on january 1 1992. Under section 1273 a the 1 000 000 excess of the stated redemption price at. See also 1017 b 3 f i basis reductions under 108 c 1 apply only to depreciable real property.

Iii under paragraph g 1 of this section the indebtedness is treated as issued to p on january 1 1992 with an issue price of 9 000 000. Section 108 c 1 provides that if a taxpayer excludes cod income under 108 a 1 d the taxpayer must reduce basis in depreciable real property by the same amount in accordance with 1017. Section 108 is the loan guarantee provision of the community development block grant cdbg program.

Thus a s deferred section 752 amount with respect to debt one and debt two equals 200 the lesser of a s aggregate deferred amounts with respect to debt one and debt two of 250 or gain that a would. The section 108 loan guarantee program section 108 provides community development block grant cdbg recipients with the ability to leverage their annual grant allocation to access low cost flexible financing for economic development housing public facility and infrastructure projects. Section 1951 b 2 b of pub.

Insolvency exclusion exclusion only applies to the extent of. If any discharge cancellation or modification of indebtedness of a railroad corporation occurs in a taxable year beginning after december 31 1976 pursuant to an order of a court in a proceeding referred to in section 108 b a or b which commenced before january 1 1960 then. The section 108 loan guarantee program section 108 provides communities with a source of low cost long term financing for economic and community development projects.

Under this section hud offers communities a source of financing for certain community development activities such as housing rehabilitation economic development and large scale physical development projects. Loan guarantee assistance for community and economic development. Communities can use section 108 guaranteed loans to either finance specific projects or to launch loan.

In the case of any discharge of indebtedness to which subparagraph a or b of section 108 a 1 of the internal revenue code of 1986 formerly i r c. Section 108 financing provides an avenue for communities to undertake larger more costly projects where they may have limited resources to invest in upfront.