In re Markus, 607 B.R. 379 (Bankr. S.D.N.Y. 2019) [click for opinion]
USA, Insolvency & Restructuring, Litigation, Baker McKenzie, Bankruptcy, Debtor, Title 11 of the US Code, United States bankruptcy court
Cancellation of debt a key element of most restructurings generally triggers taxable income. The German tax authorities had issued an administrative decree (the "Tax Restructuring Decree" - Sanierungserlass), however, declaring that, upon the satisfaction of certain requirements and conditioned on forfeiture of any loss carry forwards, the cancellation of debt income ("CODI") would not be taxed.