§1241 — Cancellation of lease or distributor’s agreement
11 cases·1 followed·1 distinguished·9 cited—9% support
Statute Text — 26 U.S.C. §1241
Amounts received by a lessee for the cancellation of a lease, or by a distributor of goods for the cancellation of a distributor’s agreement (if the distributor has a substantial capital investment in the distributorship), shall be considered as amounts received in exchange for such lease or agreement.
Treasury Regulations
- Treas. Reg. §Treas. Reg. §1.1241-1 Cancellation of lease or distributor's agreement
- Treas. Reg. §Treas. Reg. §1.1241-1(a) In general.
- Treas. Reg. §Treas. Reg. §1.1241-1(b) Definition of cancellation.
- Treas. Reg. §Treas. Reg. §1.1241-1(c) Amounts received upon cancellation of a distributorship agreement.
11 Citing Cases
1241, 100 Stat. 2085, 2579, and amended by the Small Business Job Protection Act of 1996 (1996 Act), Pub. L. 104-188, sec. 1704(f)(3), 110 Stat. 1755, 1879, provides: SEC. 884(f). Treatment of Interest Allocable to Effectively Connected Income.-- (1) In general.--In the case of a foreign corporation engaged in a trade or business in the United
1241(a), 100 Stat. 2576; Staff of Joint Comm. on Taxation, General Explanation of the Tax Reform Act of 1986, at 1036, 1037 (J. Comm. Print 1987). Generally, if services are performed in the United States, they give rise to U.S. source income, section 861(a)(3), and services performed outside the United States give rise to foreign source incom
Petitioner paid Spyropoulos legal expenses for the sole purpose of disposing of the leasehold interest in rooms 103 and 141. Thus, the legal expenditures of $22,500 are capital expenditures that are offset against the gain realized by petitioner. In exchange for vacating rooms 103 and 141, petitioner received use of the new apartment ren
terest that is treated as income from sources within the United States, if the interest is not effectively connected income to the recipient. Interest that is treated as income from sources without the United States is 25 The Tax Reform Act of 1986, sec. 1241(b)(1)(A), 100 Stat. 2579, replaced the words "residents, corporate or otherwise" in sec. 861(a)(1) with the words "noncorporate residents or domestic corporations." The current sec. 861(a)(1), therefore, does not refer to foreign corporatio
terest that is treated as income from sources within the United States, if the interest is not effectively connected income to the recipient. Interest that is treated as income from sources without the United States is 25 The Tax Reform Act of 1986, sec. 1241(b)(1)(A), 100 Stat. 2579, replaced the words "residents, corporate or otherwise" in sec. 861(a)(1) with the words "noncorporate residents or domestic corporations." The current sec. 861(a)(1), therefore, does not refer to foreign corporatio