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Which of the following statements is true regarding a below-market gift loan with no exception to the imputed interest rules?

A) The lender is not deemed to have received any interest income.
B) The imputed interest rules do not apply to below-market gift loans.
C) The lender is deemed to have received interest income, even if no interest is charged or collected.
D) The borrower is responsible for reporting imputed interest income.

User KarlR
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1 Answer

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Final answer:

For a below-market gift loan with no exceptions to the imputed interest rules, the lender is deemed to have received interest income for tax purposes, even when no actual interest is charged or collected. The correct answer is C) The lender is deemed to have received interest income, even if no interest is charged or collected.

Step-by-step explanation:

When analyzing the true economic effect of a below-market gift loan, where no exception to the imputed interest rules applies, it is important to understand how the Internal Revenue Service (IRS) views the transaction. A below-market loan is one where the interest rate is less than the applicable federal rate (AFR), which the IRS considers necessary for the loan to be considered a true market-rate transaction. In the case of a below-market gift loan with no exceptions to the imputed interest rules, the correct statement is:

C) The lender is deemed to have received interest income, even if no interest is charged or collected.

This means the IRS imputes interest on the loan. The lender must report this imputed interest income on their tax return, even though no actual interest payments are made. This is designed to prevent the lender from giving a large sum of money as a loan to avoid taxation. The borrower may also be able to deduct the implied interest expense if the loan proceeds are used for investment or business purposes, but they are not responsible for reporting imputed interest income. It's a subtle but important distinction that the IRS treats such transactions as if they were conducted at the market rate, to ensure that taxes are collected on what would have been the usual interest component of a standard transaction. The hypothetical reference to negative interest rates in the context of the question does not directly pertain to the treatment of below-market gift loans under IRS rules, which adhere to the AFR for the purpose of imputed interest.

User Ccheneson
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