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T.D. 9124 - At-Risk Limitations Interest Other Than That Of A Creditor
Get T.D. 9124 - At-Risk Limitations Interest Other Than That Of A Creditor
T.D. 9124 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 At-Risk Limitations; Interest Other Than That of a Creditor AGENCY: Internal Revenue Service (IRS), Treasury. borrowed from a person who has an interest in an activity other than that of a creditor or from a person related to a person (other than the borrower) with such an interest. These regulations affect taxpayers subject to the at-risk limitations and provide them with guidance necessary to comply with the law. DAT.
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REG20937789 FAQ
(B) Qualified nonrecourse financing For purposes of this paragraph, the term “qualified nonrecourse financing” means any financing— (i) which is borrowed by the taxpayer with respect to the activity of holding real property, (ii) which is borrowed by the taxpayer from a qualified person or represents a loan from any ...
Reg. Section 1.465-8(b)(1) provides that the lender will have an interest in the activity other than as a credit or if the lender has either a capital interest in the activity (a shareholder of the S corporation) or an interest in the net profits of the activity.
Jenner Related content
Recent Developments in Federal Income Taxation
by IB Shepard · 2004 — T.D. 9124, At-Risk. Limitations; Interest Other Than That of a...
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