Article Title
Abstract
This Article explores the tax treatment of cross-collateral nonrecourse debt. When using the term cross-collateral debt, we are referring to non¬recourse debt that is connected with more than one piece of property. While tax issues concerning cross-collateralized properties can arise in several circumstances, the focus of this Article is on the tax treatment of a transfer of property subject to a cross-collateralized nonrecourse lia¬bility to a controlled corporation in exchange for stock that qualifies for some or all nonrecognition under § 351. The Article also discusses two other tax issues involving cross-collateralized nonrecourse liability—namely, cancellation of debt and determination of basis issues.
Recommended Citation
Kahn, Douglas A. and Kahn, Jeffrey H.
(2023)
"Tax and Cross-Collateralized Nonrecourse Liability,"
Florida Tax Review: Vol. 24, Article 5.
Available at:
https://scholarship.law.ufl.edu/ftr/vol24/iss2/5