COD Income definition

COD Income means income recognized by the Partnership pursuant to Code Section 61(a)(12).
COD Income means cancellation of debt income.
COD Income has the meaning set forth in Section 6.3.C hereof.

Examples of COD Income in a sentence

  • Alternatively, a debtor with COD Income may elect first to reduce the basis of its depreciable assets pursuant to section 108(b)(5) of the Tax Code.

  • This limitation is independent of, and in addition to, the reduction of tax attributes described in the preceding section resulting from the exclusion of COD Income.

  • If a debtor member’s excluded COD Income exceeds its tax attributes, the excess COD Income is applied to reduce certain remaining consolidated tax attributes of the affiliated group.

  • In the context of a consolidated group of corporations, the tax rules provide for a complex ordering mechanism in determining how the tax attributes of one member can be reduced by the COD Income of another member.

  • Instead, as a consequence of such exclusion, a debtor must reduce its tax attributes by the amount of COD Income that it excluded from gross income pursuant to the rule discussed in the preceding sentence.


More Definitions of COD Income

COD Income means income arising from the cancellation of
COD Income the meaning set forth in Section 5.3(j).
COD Income means income realized by the Partnership on the cancellation of recourse indebtedness under federal income tax principles whether or not the income is excluded from taxable income under Section 108 of the Code or under common law principles of federal income taxation. For this purpose, indebtedness is recourse if it is treated as recourse for purposes of the Treasury Regulations under Code Section 704(b).
COD Income means income from discharge of indebtedness as defined by Internal Revenue Code §61(a)(11).
COD Income amounts realized for federal income tax purposes as a result of discharge of indebtedness.