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The Top Five Federal Tax Issues for FinTech Lenders  


Author:  James D. Goeller.; Charlie E. Shureen.


Source: Volume 30, Number 01, Fall 2016 , pp.5-10(6)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

FinTech lenders increasingly are competing with traditional bank lenders: helping underwrite loans, obtaining funding for loans, managing a wide variety of financial assets, and often selling and securitizing loans. But the fact that FinTech lenders are not subject to banking regulations, which provides them with great business flexibility, can present a host of unexpected tax issues.

Keywords: gain or loss; IRC Sec. 582(c); mark-to-market; IRC Sec. 475; hedging interest rate risk; IRC Sec.1221; deduction timing for loan losses; IRC Sec. 166; tax character of loan losses; IRC Sec.582(a)

Affiliations:  1: Crowe Horwath LLP; 2: Crowe Horwath LLP.

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