All is forgiven?

All is forgiven?

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I have been reading previous posts in relation to debt forgiveness and would appreciate if someone could clarify the tax treatment.

For example, a property investment company in financial difficulties has had it's properties sold off by a receiver on behalf of a lender and accumulated significant capital losses on the disposals.  After a period of time, the bank has fully realised their security and makes the decision to forgive the shortfall in their debt.  The write off is a taxable non trade loan relationship gain for the company.  By the time the bank's decision is taken, the company makes the gain in a later accounting period and would be liable for CT on the NTLR gain, as the capital losses forward cannot be offset.  Is this correct?

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By User deleted
05th Dec 2014 22:54

Not really enough info

Might CTA 2009 s322 apply?

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Replying to thestudyman:
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By kck44134
08th Dec 2014 08:42

Thanks

Can you outline what additional information you need?

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