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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).
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