Kollegi bar undir mig Bindandi álit Ríkisskattstjóra um skattskyldu þrotabúa fallinna fjármálafyrirtækja í slitameðferð vegna “eftirgjafar” á samþykktum kröfum – remission of debts – við gjaldþrotaskipti eða nauðasamninga.

Enska er gjarnan notuð í skoðanaskiptum hagfræðinga um tæknileg atriði, sbr. eftirfarandi svar mitt:

I would argue that there is NO remission of debts involved.

A case in point:

Original creditor A had a claim for 100 – face value.

Current creditor B bought the claim for 25 – market price.

A has revalued his claim on “pricing to market” grounds and sold it to B at “fair value”.

NB: “fair value” means “market value”.

In the real estate market, taxable profit is the difference between historical cost and (higher) resale value.

And transferable loss is the difference between historical cost and (lower) resale value.

The Commissioner of the Inland Revenue would not have it any other way.

Things are somewhat more complicated in the present case.

But ultimately the principle is the same – historical cost/face value cannot be taken as point of departure for determining taxable profit.