A monetized installment sale is a special type of installment sale whereby a seller of appreciated assets attempts to defer U.S. Federal income tax liability over a period of years while currently receiving cash or other liquid assets via a monetization transaction, such as a loan.
Pursuant to section 453 of the Internal Revenue Code, installment sale treatment allows a seller to defer recognition of a portion of the gain on the sale of an asset where at least one payment is to be received by the seller after the close of the taxable year in which the sale occurs. In a monetized installment sale, the seller defers recognition of tax on the installment sale payments while 'monetizing' the installment note via a separate, tax free borrowing.
Although the tax is deferred until the receipt of payment under the installment contract, an interest charge is imposed on installment sales above $5,000,000, except in the case of agricultural assets, which has no limitation.[1]
^"26 CFR 15a.453-1 - Installment method reporting for sales of real property and casual sales of personal property". Law.cornell.edu. Retrieved 13 January 2018.
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