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Venture Capitalists Can Receive Favorable Tax Treatment for Forgiven Loans |
The Tax Court in Dagres , (2011) 136 TC No. 12, recently ruled that Dagres, a venture capitalist, could claim a $3,635,218 business bad debt deduction on his individual tax return under Section 166(a) of the Internal Revenue Code for the amount he forgave on a loan made to a business acquaintance in order to strengthen their business relationship and ensure that the borrower would first inform him of promising investment opportunities. Under Section 166, business bad debts are deductible as ordinary deductions when the loan becomes either partially or totally worthless. On the other hand, personal bad debts are deductible as short term capital losses only when the debt becomes totally worthless. So, if you have a bad debt, you want it to be a business bad debt. In reaching its conclusion that the loan was made in connection with Dagres’ trade or business, the Tax Court determined that:Study predicts imminent irreversible planetary collapse
Drivers of a potential planetary-scale critical transition (credit: Anthony D. Barnosky et al./Nature) Using scientific theories, toy ecosystem modeling and paleontological evidence as a crystal ball, 21 scientists predict we’re on a much worse collision course with Mother Nature than currently thought . In Approaching a state-shift in Earth’s biosphere , a paper just published in Nature , the authors, whose expertise spans a multitude of disciplines, suggest our planet’s ecosystems are careenng towards an imminent, irreversible collapse. Earth’s accelerating loss of biodiversity, its climate’s increasingly extreme fluctuations, its ecosystems’ growing connectedness, and its radically changing total energy budget are precursors to reaching a planetary state threshold or tipping point.