Commentary

D9.301 Background

Corporate tax
Corporate tax | Commentary

D9.301 Background

Corporate tax | Commentary

Division D9.3     Transfer of rights to income

For updates affecting this Division please see Part D0 Updates.

Taxation of income stream transfers

D9.301 Background

In Paget v IRC1 the taxpayer held certain bearer bonds issued by the city of Budapest and similar bonds of the kingdom of Yugoslavia. Direct payment of interest on the first bonds was forbidden by the Hungarian Government and interest on the second could no longer be paid in full. Preferring to salvage what she could rather than enter into schemes of payment, the taxpayer in September 1933 sold the interest coupons due on 1 November

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