TABLE OF CONTENTS

Chapter 1

• Taxpayer May be Control to its Coverage Position 1-5
• S Corporations with Ample Accumulated Adjustments Account (AAA) 1-7
• Reasonable Compensation Considerations (S Corporations) 1-6
• Non Bona Fide Financial obligation 1-7
• Key Determinative Factors 1-1
• In General 1-1
• Forgiveness of Liability 1-7
• Equitable Rule of evidence & Duty of Consistency 1-5
• Earnings and Profits Considerations 1-7
• Distributions with Respect to Stock 1-7
• Constructive Dividend Versus Bona Fide Financial obligation 1-1
• Bona Fide Financial obligation Vs. Non Bona Fide Financial obligation 1-1

Chapter 2

• Waiver or Cancellation of Interest 2-14
• The computation of the Imputed Remove and Innovational Issue Discount In a Below-Market Term Loan 2-11
• Term Loan Defined 2-2
• Short Period Computations 2-9
• Other Exceptions 2-6
• Loans with Increasing Balances 2-10
• Loans with Decreasing Balances 2- 10
• Loans 2-1
• Interest Issues On Market Rate Loans 2-13
• In General 2-1
• Identifying a Below-Market Term Loan 2-5
• Identifying a Below-Market Demand Loan 2-3
• Identification 2-3
• Exceptions 2-6
• Demand Loans with Declared Interest at or above AFR 2-13 Market Rate Term Loans 2-13
• Demand Loan Defined 2-2
• De Minimis Exception 2-6
• Computations 2-8
• Computation of Forgone Interest in a Below-Market Demand Loan 2-8
• Bona Fide Financial obligation (Mechanics of) 2-1
• Below Market Loans 2-1
• Balance Outstanding for the Entire Year 2-8
• Applicable Federal Rates 2-3