Web(i) Section 7872 shall not apply to a below-market loan (other than a compensation-related loan or a corporation-shareholder loan where the borrower is a shareholder that is not a … WebSection 7872 presumes that if a loan to which the section applies does not specify an interest rate, it then entails two transactions: a transfer by the lender to the borrower of …
Avoiding the Below-Market Rules on Corporation/Shareholder
WebJan 1, 2009 · IRC Section 7872(c)(1)(B) provides that a below-market loan is compensation-related if it is directly or indirectly between (1) an employer and an employee, or (2) an independent contractor and the person for whom the independent contractor provides services. (3.) IRC Section 7872(f)(5). WebI.R.C. § 7872(c)(1)(C) provides, with exceptions not relevant here, that this section shall apply to any below-market loan directly or indirectly between a corporation and any … darryl j tompkins alachua fl
How Can “Friendly” Loans Impact Your Tax Liabilities?
Web3 hours ago · Apr. 15, 2024 7:34 AM ET. Wall Street Breakfast. 5.75M Follower s. Listen on the go! A daily podcast of Wall Street Breakfast will be available by 8:00 a.m. on Seeking Alpha, iTunes, Stitcher and ... WebMar 23, 2024 · You should probably ask the CPA firm for their records as to why they classified the funds in the manner they did. I also suggest that you consider the rules of IRC Section 7872 (c) (1) (C), corporation - shareholder loans. Especially if the funds classified as loans do not carry any stated interest and interest has not been paid. Webas defined in section 7872 (c)(1)(D). (b) List of exemptions. Except as pro-vided in paragraph (a) of this section, the following transactions are exempt from section 7872: (1) Loans which are made available by the lender to the general public on the same terms and conditions and which are consistent with the lender’s customary business practice; darryl kavanagh cardiff