Debt and Interest: Deductibility, Special Calculation Concepts & Provisions
This course focuses on tax issues affecting the treatment of debt and interest deductibility. It covers the definition of bona fide debt, the impact of related parties, the avoidance of equity and lease characterization, and deductible versus nondeductible interest factors. Sticky cross issues such as the impact of at-risk rules under §465, passive loss restrictions of §469, and below-market rate loans under §7278 are examined.