For a more detailed overview, please see our previous client alert, Commercial Real Estate Partnership Cancellation of Debt Income.
The Qualified Real Property Business Indebtedness Exception
Cancelled debt is not included in gross income if, “in the case of a taxpayer other than a C corporation, the indebtedness discharged is qualified real property business indebtedness[.]” IRC § 108(a)(1)(D)(emphasis added).
Qualified real property business indebtedness (QRPBI) is defined…