debt instrument


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Upon disposition of an original issue debt instrument, the taxable gain or loss realized is generally the sale price of the debt instrument (or the redemption price if the bond is redeemed) minus the adjusted tax basis.
A modification of a debt instrument is defined broadly as any alteration, including any deletion or addition, in whole or in part, of a legal right or obligation of the issuer or a holder, whether evidenced by an express agreement (oral or written), conduct of the parties, or otherwise.
988 transaction includes acquiring or becoming the obligor under a nonfunctional currency--denominated debt instrument and entering into or acquiring any nonfunctional currency--denominated forward contract, futures contract, option, or similar instrument.
1273(b)(3), the issue price of a debt instrument that is issued for property where there is public trading is its fair market value (FMV).
Thus, the conversion of the debt instrument and the new dollar obligation are treated as replacement debt.
1001-3, which was amended in 2011, lays out the rules under which the alteration of terms of the old debt instrument will be deemed a taxable exchange.
The allocation of payments of OID made under a debt instrument before maturity between the disqualified portion and the remainder is to be made pursuant to Treasury regulations.
The rating of the following debt instrument issued by Gerling Konzern Allgemeine Versicherungs-AG has been upgraded to "bbb+" from "bbb", removed from under review and assigned a stable outlook:
Example 1: A debt instrument is originally issued at $100,000 with a 6% coupon rate.
90-3, Definition of the Term "Substantially the Same"for Holders of Debt Instrument8, as Used in Certain Audit Guides and Statements of Position, the American Institute of CPAs finally provides guidance for determining whether two debt instruments are substantially the same for the purpose of deciding if a transaction results in the culmination of the earnings process.
Treasury and the IRS plan to update regulations that affect the taxation of debt workouts--transactions in which a debtor and creditor either modify the terms of a debt instrument or replace the debt instrument with a new one (see Department of Treasury Office of Tax Policy and IRS, 2009-2010 Priority Guidance Plan 12 (November 24, 2009) (listing planned guidance projects)).
Mortgage refinancing at a lower rate obtained in the open market is a non-tax issue, as is a rate reduction that is part of the original debt instrument such as the lowering of the interest rate on an adjustable rate mortgage.
The issuer of a publicly offered debt instrument that has OID must file Form 8281 within 30 days of issuance, and issuers who willfully report late or not at all are subject to a penalty of 1 percent of the issue price, up to a maximum of $50,000.