Authors:Hugh M.
USA, Insolvency & Restructuring, Troutman Pepper, Employee Retirement Income Security Act 1974 (USA), Due diligence, Coronavirus, Title 11 of the US Code
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.