Abstract
This Article explores the tax treatment of cross-collateral nonrecourse debt. When using the term cross-collateral debt, we are referring to nonrecourse 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 liability 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
Douglas A. Kahn and Jeffrey H. Kahn,
Tax and Cross-Collateralized Nonrecourse Liability,
24 Fla. Tax Rev.
(2021).
Available at: https://scholarship.law.ufl.edu/ftr/vol24/iss2/5