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Taxation In Stockholders' Forgiveness Of Accrued Salaries, Ronald B. Cohen

Cleveland State Law Review

Cancellation of indebtedness ordinarily will be treated as income to a debtor corporation unless the debt was forgiven by a stockholder. In the latter case, the corporation normally treats the resulting benefit as a contribution to capital. However, there is a much more delicate situation when the debt is the result of unpaid salaries, interest, or other corporation expenses. In the typical case, these items would have reduced the income of the corporation in the year of accrual, but would not have been picked up as income by the cash basis stockholder. Therefore, the effective result of forgiveness of salaries …