RP-2014-20

Internal Revenue Service (IRS) sent this bulletin at 02/05/2014 04:30 PM EST

IRS GuideWire

February 5, 2014

News Essentials

IRS Resources

Compliance & Enforcement

Contact My Local Office

Filing Options

Forms & Pubs

Frequently Asked Questions

News

Taxpayer Advocate

Where to File

Issue Number: RP-2014-20

Inside This Issue

Revenue Procedure 2014-20 provides a safe harbor under which the Internal Revenue Service will, under certain, defined circumstances, treat indebtedness that is secured by 100 percent of the ownership interest in a disregarded entity that holds real property as indebtedness that is secured by real property for purposes of § 108(c)(3)(A) of the Internal Revenue Code. This revenue procedure will assist taxpayers with so-called “mezzanine” financing in workouts and similar circumstances.

Revenue Procedure 2014-20, will be in Internal Revenue Bulletin 2014-09 on Feb. 24, 2014.

Thank you for subscribing to IRS GuideWire, an IRS e-mail service. If you are a Tax Professional and have a specific concern about your tax situation, call the IRS Practitioner Priority Service 1-866-860-4259.

This message was distributed automatically from the IRS GuideWire mailing list. Please Do Not Reply To This Message.

Update your subscriptions, modify your password or email address, or stop subscriptions at any time on your Subscriber Preferences Page. You will need to use your email address to log in. If you have questions or problems with the subscription service, please contact subscriberhelp.govdelivery.com.

This service is provided to you at no charge by the Internal Revenue Service (IRS).