Ezra Dyckman and Charles S. Nelson IRS Cracks Down on Monetized Installment Sales
In recent years, promotors have marketed so-called "monetized installment sales," which would purportedly allow a seller to benefit from installment sale treatment while still effectively receiving the cash proceeds in the year of the sale. In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the IRS's Chief Counsel Advice Memorandum which explains why such transactions should not be respected for income tax purposes.
October 26, 2021 at 10:00 AM
4 minute read
If property is sold in a transaction in which the seller is to receive one or more payments at a future date, the transaction will generally be treated as an installment sale for federal income tax purposes. This can allow the seller to recognize gain from the sale as payments are received rather than entirely upfront in the year of the sale.
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