Discussion:Extinguishment of Debt

From TaxAlmanac, A Free Online Resource for Tax Professionals
Note: You are using this website at your own risk, subject to our Disclaimer and Website Use and Contribution Terms.

From TaxAlmanac

Jump to: navigation, search

Discussion Forum Index --> Accounting Questions --> Extinguishment of Debt

Mochadaw (talk|edits) said:

10 January 2008
I'm experiencing a headache researching this issue. Any guidance would be greatly appreciated.

ABC, LLC has a significant balance due 3 of its members for past services (i.e. past guaranteed payments). The members agreed to defer the amount in the prior 2 years and decided to forgive the debt this year. The question is whether or not the partnership should recognize an extraordinary income as a result of the COD or treat the COD as additional contribution from members under U.S. GAAP.

Natalie (talk|edits) said:

January 10, 2008
Generally when debt is forgiven, the result is forgiveness of debt income. (It is not considered extraordinary but may be classified as other income.)

Kevinh5 (talk|edits) said:

10 January 2008
if no deduction was taken by the business for the GP, why would it be income to the LLC now that the member chose not to take it?

CrowJD (talk|edits) said:

10 January 2008
Mochadaw, you are WAY far ahead of the curve on this issue. I was wondering when folks would start figuring out that a GP was a GP. As in "I'll just manipulate this number to arrive at what we'll pay SE tax on. We'll play around with the figure, it means nothing." Whoa. Take a look at your liabilities on the balance sheet, and see if they're listed to begin with. Also, please give your profile because I think we will all have an interest in this post going forward.

Natalie (talk|edits) said:

January 10, 2008
Kevin, the tax side of this is another consideration. On the GAAP side, however, if there is a liability, then there would have (or should have) been an expense. In that case, income would be necessary, unless a prior period adjustment were booked.

Mochadaw (talk|edits) said:

14 January 2008
Natalie,

Expense was booked the year the expense was incurred. My concern with recognizing income is that this gives the members a way to control the bottom line. I'm leaning toward booking the revenue but wanted to see if there is anything in GAAP that would prohibit me from doing so.

Natalie (talk|edits) said:

January 14, 2008
Good point about manipulation of the numbers. Is the amount significant? Why is it being forgiven? Perhaps a prior period adjustment should be recorded. At least that way they wouldn't be able to increase the bottom line just by saying we're not going to pay ourselves.

Mochadaw (talk|edits) said:

14 January 2008
The liability is being written off as a result of a reorganization of the partnership. The members agreed to waive it. I don't recall if the member interest would be different without the waiver. If so, it seems to be a quid pro quo demand to me. Thus it would justify treatment of COD as additional capital contributions. What's your thoughts on this?

Natalie (talk|edits) said:

January 14, 2008
Given that the partnership is going through reorganization, it does not seem that manipulation of the numbers was the intent here. Is this issue addressed in the reorganization documents?

GregC8579 (talk|edits) said:

14 January 2008
Mochadaw - If you are looking at this from a GAAP perspective, then I believe your authority can be found in FASB 15 - Accounting for Creditors and Debtors in Toubled Debt Restructurings. When the debt it is forgiven it is considered a gain on debt restructuring and is presented in the "other gains and losses" category of the income statement.

Mochadaw (talk|edits) said:

January 15, 2008
Thanks for the tip Greg. I'll look into it right away.

Mochadaw (talk|edits) said:

January 17, 2008
Further research in Current Text shows that equity treatment is appropriate per APB Opinion 26. Thank you all for your valuable input.

To join in on this discussion, you must first log in.
Personal tools