top of page
Legal Authority
for Installment Sales Coupled with a Loan
Public Companies' Version
(Click for Documents)
-
Executive Summary - Overview of Monetized Installment Sales
-
IRS - Private Letter Ruling 20123401f allowing a Monetized Installment Sale
-
SEC - Summary of 10 Public Companies Utilizing Monetized Installment Sales
-
Federal Bankruptcy Court - Approval of Monetized Installment Sale of California beach home (with notice to IRS)
-
American Bar Association Meeting - Discussing Installment Sales (favorably for Monetized Installment Sales and Unfavorably about Deferred Sales Trusts), with IRS officials present, 2016 (audio file)
-
Law Review Article - Monetizing Installment Sale Transactions, Corporate Taxation (WG&L), Nov/Dec 2004
-
Law Summary - Judicial doctrines pertaining to tax related transactions, including business purpose, step transaction doctrine, assignment of income, etc.
-
Statute Allowing 'flipping' the asset and IRS awareness of transaction.
-
Four Recent Cases Allowing Tax Motivated Transactions. (Coltec, IES, ACM Partnership, Summa Holding).
CONTACT
Us
Email Us
Tel: (408) 657-3760
For any general inquiries, please fill in the following contact form:
bottom of page