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ARTICLE · 29 JULY 2020

Could Future COVID-19 Relief Allow COD Income Deferral?

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Tax relief for debt workouts could play a critical role in facilitating our economic recovery.

United StatesCoronavirus (COVID-19)
Stuart E. Leblang
Stuart E. Leblang
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Tax relief for debt workouts could play a critical role in facilitating our economic recovery. As companies feel the squeeze from coronavirus shutdowns, one natural option would be to turn back on Section 108(i), a temporary provision from 2009 that allowed certain taxpayers to elect to defer cancellation of debt (COD) income. We understand that resurrecting Section 108(i) is coming up on calls between companies and policy advocates. We would not be surprised if these discussions coalesce in an effort to include the provision in future legislation aimed at providing relief for businesses struggling with the COVID-19 outbreak.

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