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| Author : | Danny C Santucci, JD |
| Course Length : | Pages: 0 ||| Review Questions: 0 ||| Final Exam Questions: 100 |
| CPE Credits : | 20.0 |
| IRS Credits : | 20 |
| Price : | $129.95 |
| Passing Score : | 70% |
| Course Type: | NASBA QAS - Text - NASBA Registry - IRS Enrolled Agents |
| Technical Designation: | Technical |
| Primary Subject-Field Of Study: | Taxes - Taxes for Course Id 1076 |
| Description : | This course brings the practitioner up-to-date information on tax issues affecting interest and debt. It covers the definition of bona fide debt, the avoidance of equity and lease treatment, imputed interest rates and debt modification. The various types of interest and their required allocation are explored and reviewed. For the economically troubled client, special attention is devoted to debt cancellation, repossession, discounts, and foreclosure. The program also discusses installment sales, equity participation debt, taxable interest, and bad debts. |
| Usage Rank : | 0 |
| Release : | 2016 |
| Version : | 1.0 |
| Prerequisites : | General understanding of federal income taxation. |
| Experience Level : | Overview |
| Additional Contents : | Complete, no additional material needed |
| Additional Links : |
Letters Rejigged RAH deal avoids interest blow out scrutiny
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| Advance Preparation : | None |
| Delivery Method : | Self-Study |
| Intended Participants : | Anyone needing Continuing Professional Education (CPE) |
| Revision Date : | 10-May-2016 |
| NASBA Course Declaration : | Participants must complete the final examination within one year of purchase and with a minimum passing grade of 70% or better to receive CPE credit unless otherwise noted on the Course History page (i.e. California Ethics must score 90% or better). After logging in click on the Course History links on your My Courses page for the Begin date and Expire date for the Final Exam. |
| Approved Audience : | NASBA QAS - Text - NASBA Registry - IRS Enrolled Agents - 1076 |
| Keywords : | Taxes, Dealing, Debt, InterestBlowout, cpe, cpa, online course |
| Learning Objectives : | A |
| Course Contents : | Chapter 1 - Deductible Interest & Debt Introduction Indebtedness Bona Fide Debt Economic Substance Business Purpose Related Party Debt Inter-Family Loans Loans to Controlled Corporation Losses Debt v. Stock Factors Debt v. Lease Traditional Lease Leveraged Leases Debt v. Annuity Deductible Interest Business Interest Mortgage Interest Prepayment Penalty Points Expenses to Obtain a Mortgage Interest on Installment Purchases Investment Interest Investment Property Limit on Deduction Net Investment Income Investment Income Capital Gain Inclusion Election Child’s Investment Income Investment Expenses Losses from Passive Activities Carryover When to Deduct Investment Interest Form 4952 Interest Paid In Advance Interest on Margin Accounts Interest on a Market Discount Bond Disallowed Interest Expense Deduction for Student Loan Interest - §221 Nondeductible Interest Personal Interest Qualified Residence Interest Exception Acquisition Indebtedness Home Equity Indebtedness Interest on Income Tax Owed Penalties Capitalized Interest Production Period Traced Debt Avoided Cost Debt When Interest Is Paid or Incurred Partnerships & S Corporations Interest Related To Tax-Exempt Income Interest on Insurance Policy Loans Single Premium Life Insurance Systematic Plan of Borrowing Key Person Insurance Deductibility of Premiums & Interest on Life Insurance Existing Interest on Purchase Commitment Fees & Service Charges Corporate Acquisition Interest - §279 At-Risk Rules - §465 Loss Defined Form 6198 Activities Covered by the At-Risk Rules Amount At Risk Borrowed Amounts Related Persons Subsequent Years Amounts Not At Risk Nonrecourse Financing Other Loss Limiting Arrangements Reductions of Amounts At Risk Passive Activity Limitations - §469 Calculating Passive Loss Categories of Income & Loss Passive Portfolio Material Participation Suspension of Disallowed Losses Fully Taxable Disposition Abandonment & Worthlessness Related party Transactions Other Transfers Transfer By Reason Of Death - §469(g)(2) Transfer By Gift - §469(j)(6) Installment Ordering of Losses Carryforwards Allocation of Suspended Losses Rental Activity Rental Activities of Real Estate Professionals Working Interests in Oil & Gas When to Deduct Interest Cash Method Prepaid Interest Points Exception for Points on Home Discounted Loans Refunds of Interest Accrual Method Prepaid Interest Tax Deficiency Related Taxpayer - §267 Election to Capitalize Carrying Charges - §266 Below-Market Interest Rate Loans - §7872 Demand Loans (Gift or Nongift) - §7872(a) Forgone Interest - §7872(e)(2) Term Gift Loans - §7872(d)(2) Nongift Term Loans - §7872(b) Loans Subject To the Rules Exceptions Special Rule for Certain Gift Loans Loans Not Subject To the Rules Tax Avoidance Loans Significant Effect on Federal Tax Liability Loans to Qualified Continuing Care Facilities Continuing Care Facility Continuing Care Contract Imputed Interest on Sales - §483 & §1271 through 1275 Applicable Federal Rate (AFR) Effects of Unstated Interest Selling Price & Contract Price Rules for Imputing Interest Test Rate of Interest Relationship of §1274 & §483 Section 483 Total Unstated Interest Transactions to Which Section 483 Rules Apply Sales with Total Payments of $250,000 Or Less Land Sales Between Related Parties Exceptions to §483 Rules Section 1274 Rules Exceptions to §483 & §1274 Original Issue Discount (OID) De Minimis OID Form 1099-OID Nominee Debt Instrument Bought At Premium Exceptions to OID Rules Debt Instruments Issued From 1955 to 5/28/69 Corporate Debt Instruments Issued From 5/28/69 to 7/2/82 Debt Instruments Issued From 7/2/82 to 1/1/85 Debt Instruments Issued After 12/31/84 Recomputation of OID on Form 1099-OID Acquisition Premium REMIC Regular Interests Certificates of Deposit (CDs) Interest Subject To Penalty for Early Withdrawal Bearer Certificates Of Deposit Market Discount Bonds Chapter 2 - Allocation of Deductible Interest Introduction Use of Proceeds Allocation Period Proceeds Not Disbursed To Borrower Proceeds Deposited in Borrower’s Account Order of Funds Spent Expenditures Paid From Checking Accounts Expenses Paid Within 30 Days Optional Method for Determining Date of Reallocation Interest on a Separate Account Accrued Interest Accrued Interest Before Debt Proceeds Are Received Loan Proceeds Received In Cash Loan Repayments Continuous Borrowings Loan Refinancing Partnerships & S Corporations Debt-Financed Acquisitions Reallocation How to Report Debt-financed Distributions Optional Method How to Report Chapter 3 - Home Mortgage Interest Secured Debt Unsecured Debt Wraparound Mortgage Treating Debt as Unsecured Qualified Home Second Home Divided Use of Home Construction Time-Sharing Married Taxpayers Special Situations Late Payment Charge Prepayment Penalty Prepaid Interest Mortgage Interest Credit Ministers’ & Military Housing Shared Appreciation Mortgage (SAM) Graduated Payment Mortgages (GPM) Mortgage Assistance Payments Ground Rent Redeemable Ground Rent Nonredeemable Ground Rent Reverse Mortgage Loans Refunds of Interest Cooperative Apartment Owner Points General Rule Exception - Fully Deductible Points Service Charges Seller Paid Points Funds Provided Are Less than Points Excess Points Mortgage Ending Early Refinancing Mortgage Interest Statement - Form 1098 Special Rule for Cooperative Housing Cooperative Housing Corporation Debt Secured by Stock Determining Home Mortgage Interest Limits on Home Mortgage Interest Home Acquisition Debt Home Acquisition Debt Limit Refinanced Home Acquisition Debt Mortgage Deemed Used To Buy, Build, or Improve Home Date of the Mortgage Cost of Home or Improvements Substantial Improvement Home Equity Debt Home Equity Debt Limit Fair Market Value Mixed-Use Mortgages Grandfathered Debt Refinanced Grandfathered Debt Exception Line-of-Credit Mortgage Chapter 4 - Taxable Interest Dividends vs. Interest Interest on Insurance Dividends Prepaid Insurance Premiums CDs & Deferred Interest Accounts Borrowing To Invest In CDs Gift for Opening Account Interest Income on Frozen Deposits Treasury Bills Treasury Notes & Bonds Miscellaneous Interest Items Interest on Tax Refunds Interest on Condemnation Award Installment Interest on Annuity Contract Usurious Interest Interest on Money Deposited With a Stockbroker Accrued Interest on Bonds Bonds Traded Flat Below-Market Loans Series HH Bonds Series EE Bonds Change From Method 1 Change From Method 2 Bonds Held Beyond Maturity Co-owners Child as Only Owner Choice to Report Interest Each Year Ownership Transferred Purchased Jointly Transfer to a Trust Decedents Savings Bonds Traded $500 Minimum Value Choice to Report Interest in Year of Trade Form 1099-INT for Education Savings Bond Program Qualified Eligible Expenses Eligible Educational Institutions Amount Excludable Exclusion Reduced For Certain Benefits Modified Adjusted Gross Income Limit Record keeping Verification by IRS Bonds Sold Between Interest Dates Insurance Specified Number of Installments Specified Amount Payable Installments for Life Interest Option on Insurance Annuity State or Local Government Obligations Tax-Exempt Interest on State or Local Obligations Information-Reporting Requirement Empowerment Zone or Taxable Interest on State or Local Obligations Mortgage Revenue Bonds Arbitrage Bonds Private Activity Bonds Tax-Exempt Bonds Bought at a Discount Stripped Tax-exempt Bonds or Coupons Redeemed Before Maturity Market Discount on Tax-Exempt Bonds Chapter 5 - Installment Sales Installment Method Requirements Formula Dealers Special Rule Installment Income Interest Income Gain Definitions Selling Price Selling Price Reduction Allocation Basis & Adjusted Basis Installment Selling Expense Gross Profit Contract Price Gross Profit Percentage Income from Payments in Year of Electing Out of the Installment Method Selling Price Fair Market Value How to Elect Out When to Elect Out Payments Buyer’s Note Assumed Expenses Mortgage Assumed Mortgage Less Than Basis Mortgage More Than Basis Wrap-around Mortgages Mortgage Canceled Debts Payments of Property Fair Market Value Third-Party Notes Bonds Guarantees Deposits Pledging Limit on Payment Treatment Exception Escrow Accounts Escrow Established In a Later Year Substantial Restriction Recapture Imputed Interest & OID Complexity Section 483 - Imputed Interest Exemptions Imputed Interest Rates Small Transaction Exception Intra-family Land Exception Timing Sections 1271-1274 & OID OID Rates Timing Cash Method Debt Instrument Exception Computation of OID Personal Use Property - Buyer’s Deduction of Imputed Interest Repossession Section 1038 - Repossession by Seller Repossession of Principal Residence Related Party Sales Exception Resale Rule Related Persons Exceptions Like-Kind Exchanges Installment Payments Final Regulations & Delayed Exchanges Contingent Payments or Price Installment Sales Revision Act of 1980 Contingent Payment Maximum Selling Price Transactions Recomputation Fixed Payment Term Transactions Losses Transactions with Neither Maximum Selling or Fixed Payment Term Losses Income Forecast Method Election Calculation Special Rules Qualification Single Residual Method How to report Inventory Dealer Dispositions Definition Residential Lot & Timeshare Exception Interest Computation Qualification Installment Notes in Excess of $5 Million Computation of Interest Definitions Pledging Dispositions of Installment Obligations Gain or Loss Exceptions Substitution Tax-free Transfers Transfers Between Spouses Or Former Spouses Gifts Cancellation Forgiving Part of the Debt Assumptions Death Transfers Basis Chapter 6 - Repossession Personal Property Non-Installment Method Sales Basis of Installment Obligation Gain or Loss on Repossession Installment Method Sales Basis of Installment Obligation Gain or Loss on Repossession Basis of Repossessed Personal Property Bad Debt Real Property Conditions Figuring Gain on Repossession Limit on Taxable Gain Repossession Costs Indefinite Selling Price Character of Gain Basis of Repossessed Real Property Holding Period for Resales Buyer Improvements Bad Debt Seller’s Former Home Exception Chapter 7 - Debt Cancellation & Foreclosure Income Inclusion Rule Exceptions from Income Inclusion Order of Exclusions Bankruptcy Case Exclusion - §108(a)(1)(A) Insolvency Exception - §108(a)(1)(B) Qualified Farm Debt Exclusion - §108(a)(1)(C) Qualified Farm Debt - §108(g)(2) Qualified Person - §108(g)(1) Real Property Business Debt - §108(a)(1)(D) Qualified Debt Exclusion Limit Ordinary Income Recapture Partnerships Deemed Distribution Rules S Corporations Student Loan Exception - §108(f) Tax-Exempt Educational Organizations - §108 Purchase Money Debt Reduction Exception - §108(e)(5) Cancellation of Deductible Debt Exception - §108(e)(2) Reduction of Tax Benefits (Attributes) - §108(b) General Ordering of Tax Attribute Reduction Basis Reduction Depreciable Property Election Procedure Required Reduction Timing of Basis Reduction Limit on Basis Reduction Recapture of Basis Reductions Exempt Property Special Basis Reduction Rule for Qualified Farm Debt Qualified Property Basis Reduction Order Exclusion Limit Individual Bankruptcy Partnership Bankruptcy Depreciable Property Allocation of Debt-Discharge Income Corporate Stock-For-Debt Rule Token Share Inclusion Workout Inclusion Recapture of Gain on Later Debt Contributed to Capital Debt-For-Debt Exchange Earnings & Profits S Corporation Bankruptcy Net Operating Losses Adjustments to Shareholder’s Basis in Debt Bankruptcy Estate as Shareholder Reporting Amount Realized On Foreclosure Nonrecourse Indebtedness Recourse Indebtedness Reporting Form 1099A Timing & Character of Gain or Loss Gain Loss Mortgage Debt Relief Act of 2007 (Expired) Qualified Principal Residence Indebtedness Mixed Indebtedness Lender’s Tax Impact Foreclosure Discounted Acquisition of Debt Transactions Involving Related Parties Related Persons Chapter 8 - Equity Participation Debt Shared Appreciation Mortgages - SAMs Examples Put & Call Equity Investment Loan with Option Net Cash Flow Participation Incremental Participation Common Elements Characteristics of A SAM Appreciation Definition Perspective Importance to Borrowers Economic Compromise Expiration of Term Importance for the Lender Tax Treatment Overview Hybrid Concept Revenue Ruling 83-51 Types of Equity Participation Debt Contingent Interest Option or Conversion Right Contingent Interest as the Measure & Means of Equity Participation Basic Tests to Establish Interest Application to Equity Participation Farley Realty Corp Kena, Inc. Caselaw Factors Revenue Ruling 83-51 Significance of R.R. 83-51 Limitations Corporate Application & §385 Analogy 50% Cut Off Rule Computation Locked Interest Exception Application to SAMs Value of Debt vs. Equity Features Non-Corporate Borrowers Partnership Recharacterization - Culbertson Rule Control Mayer Case Walsh Case Profits & Losses Hartman Case Walsh & Wheeler Cases Intent Tax Consequences of Debt Recharacterization Confirming Debtor/Creditor Status Failure to Find Debtor/Creditor Status - Recharacterization Interest Contingent Interest as Preference Return Revenue Ruling 81-300 Fixed Interest as Guaranteed Payments Distributions Partnership Income & Loss Determining Distributive Share Allocation Nonrecourse “Loan” Recourse “Loan” Section 704(d) - Basis Limit on Deductions Basis & Section 752 Who Gets Basis For The “Debt”? Option & Conversion Rights The “True” Option Rule Recharacterization Risk Original Issue Discount - A Special Issue for Conversion & Option Rights TRA ‘69 & ‘84 - Application of OID to Options Section 1273 - Element Allocation Rule Section 1272 - Daily Income Concept Convertible Indebtedness - A Different Rule Rationale Tax Consequences of Conversion Conversion to Partnership Interest Conversion to Direct Ownership Imputed Interest & Original Issue Discount Separate Concepts Original Issue Discount (“OID”) Definition Stated Redemption Price Issue Price Summary Imputed Interest General Rule & Test Rate Regulations’ Escape Hatch Accounting Treatment APB No. 21 Summary Chapter 9 - Foreign Interest Withholding Fixed or Determinable Annual or Periodic Income Interest Subject to Withholding Interest Paid By Interest on Real Property Mortgages Interest Paid To Controlling Foreign Corporations Interest Paid By Foreign Corporations Statutory Tax Treaties Interest on Tax-Free Covenant Bonds Statutory Interest Exempt from Withholding Interest on Deposits Payer Having Income from Abroad Bankers’ Acceptances Sales of Bonds Between Interest Dates Portfolio Interest Unregistered Obligations Registered Obligations Registered Obligations Targeted To Foreign Markets Nonqualifying Payees Contingent Interest Rule Exceptions Chapter 10 - Bad Debts Non-Business Bad Debts Totally Worthless Determining Worthlessness Required Basis or Income Inclusion True Debt Loan or Gift Loan Guarantees Political Debts Mechanics’ Liens Insolvency of Contractor Secondary Liability on Home Mortgage Reporting Recovery Business Bad Debts Credit Transactions Income Inclusion Accrual Method Taxpayers Cash Method Taxpayers Former Business Debt Acquired from a Decedent Political Debts Insolvency of Partner Business Loan Guarantees Reporting Methods of Treating Bad Debts Specific Charge-Off Method Partly Worthless Debts Deduction Disallowed Totally Worthless Debts Recovery of Bad Debt Property Received for a Debt Bankruptcy Claim Net operating Loss Nonaccrual-Experience Accounting Method Performing Services Interest & Late Charges Glossary |
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