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Shareholder Loans Edition

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IRS Tax Audit Manual for Shareholder Loans 

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TABLE OF CONTENTS

  • Introduction vii
  • Chapter 1
    • Constructive Dividend Versus Bona Fide Debt 1-1
    • Bona Fide Debt Vs. Non Bona Fide Debt 1-1
    • In General 1-1
    • Key Determinative Factors 1-1
    • Taxpayer May be Held to its Reporting Position 1-5
    • Equitable Estoppel & Duty of Consistency 1-5
    • Reasonable Compensation Considerations (S Corporations) 1-6
    • Non Bona Fide Debt 1-7
    • S Corporations with Ample Accumulated Adjustments Account (AAA) 1-7
    • Forgiveness of Indebtedness 1-7
    • Distributions with Respect to Stock 1-7
    • Earnings and Profits Considerations 1-7
  • Chapter 2
    • Bona Fide Debt (Mechanics of) 2-1
    • Below Market Loans 2-1
    • In General 2-1
    • Loans 2-1
    • Demand Loan Defined 2-2
    • Term Loan Defined 2-2
    • Applicable Federal Rates 2-3
    • Identification 2-3
    • Identifying a Below-Market Demand Loan 2-3
    • Identifying a Below-Market Term Loan 2-5
    • Exceptions 2-6
    • De Minimis Exception 2-6
    • Other Exceptions 2-6
    • Computations 2-8
    • Computation of Forgone Interest in a Below-Market Demand Loan 2-8
    • Balance Outstanding for the Entire Year 2-8
    • Short Period Computations 2-9
    • Loans with Increasing Balances 2-10
    • Loans with Decreasing Balances 2- 10
    • The computation of the Imputed Transfer and Original Issue Discount In a Below-Market Term Loan 2-11
    • Interest Issues On Market Rate Loans 2-13
    • Demand Loans with Stated Interest at or above AFR 2-13 Market Rate Term Loans 2-13
    • Waiver or Cancellation of Interest 2-14
  • APPENDIX A
    • BELOW-MARKET TERM LOAN EXAMPLE A-1
  • APPENDIX B
    • BELOW-MARKET DEMAND LOAN EXAMPLE B-1
  • APPENDIX C
    • KEY COURT CASES C-1
Don’t forget – The IRS Tax Audit Manual for Shareholder Loans is tax deductible as a business expense!