COD Income definition

COD Income means income recognized by the Partnership pursuant to Code Section 61(a)(12).

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COD Income has the meaning set forth in Section 6.2.I hereof.

COD Income means cancellation of debt income.

Examples of COD Income in a sentence

• However, such cancellation of Asbestos Claims generally will not result in COD Income to Reorganized Congoleum because payment of the Asbestos Claims would have given rise to tax deductions for Reorganized Congoleum.

• In general, a taxpayer must include in gross income the amount of any indebtedness that is cancelled ("COD Income") during the taxable year.

• Additionally, Section 108(e)(2) of the IRC provides that no COD Income is realized to the extent that the taxpayer's satisfaction of the cancelled debt would have given rise to a tax deduction for United States federal income tax purposes.

• In this event, rather than being included in gross income, the COD Income is applied to reduce the following tax attributes of the taxpayer in the following order: net operating losses, business and minimum tax credit carry forwards, capital loss carry forwards, the basis of the taxpayer's assets, and foreign tax credit carry forwards (collectively, the "Tax Attributes").

• Notwithstanding the foregoing, in the event that the discharge of indebtedness pursuant to the Plan were to cause Reorganized Congoleum to recognize COD Income, Congoleum has not yet determined whether it would make the election under Section 108(b)(5) of the IRC to apply any required Tax Attribute reduction first to depreciable property, with any excess next applied to reduce other Tax Attributes.

More Definitions of COD Income

COD Income means cancellation of indebtedness income.

COD Income the meaning set forth in Section 5.3(j).

COD Income means income arising from the cancellation of

COD Income means the cancellation of indebtedness income resulting from the discharge of Claims against the EFH Debtors and EFIH under the Plan.

COD Income means income realized by the Company on the cancellation of recourse indebtedness under federal income tax principles whether or not the income is excluded from taxable income under IRC Section 108 or under common law principles of federal income taxation. For this purpose, indebtedness is recourse if it is treated as recourse for purposes of the Treasury Regulation under IRC Section 704(b).

COD Income means income realized by the Partnership on the cancellation of recourse indebtedness under federal income tax principles whether or not the income is excluded from taxable income under Section 108 of the Code or under common law principles of federal income taxation. For this purpose, indebtedness is recourse if it is treated as recourse for purposes of the Treasury Regulations under Code Section 704(b).

COD Income has the meaning set forth in Section 6.3(c) of this Agreement.