• IRS Changes Rules for COD Income
  • October 29, 2003 | Authors: Richard J. Bronstein; Peter J. Rothenberg
  • Law Firm: Paul, Weiss, Rifkind, Wharton & Garrison LLP - New York Office
  • On September 4, 2003, just in time for a scheduled confirmation hearing on MCI's bankruptcy reorganization plan, the Treasury Department has published temporary regulations that will significantly (and adversely) affect the tax profile of many debtors emerging from bankruptcy. In particular, the new temporary regulations address the method of tax attribute reduction that results from cancellation of indebtedness ("COD") income incurred by a member of a consolidated group in a title 11 case.