Speaking on the occasion PSX Chairman Muneer Kamal said it is the first debt instrument
that has been classified as ADT1 capital by the central bank.
The determination of whether a covered debt instrument
is issued with the principal purpose of funding a distribution or acquisition is determined based upon all of the facts and circumstances.
Taxpayer intended to issue a convertible debt instrument
(the convertible note) to Parent in exchange for money.
The IRS issued final and temporary regulations providing rules for brokers to report bond premium and acquisition premium as well as governing information reporting of transactions involving debt instruments
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.
When the Islamic banks start operations, the deposit growth (or growth on the liability side) will be much higher than the anticipated growth in asset side and the Sharia-compliant banks will find it extremely difficult to invest their deposits, if there is a lack of Islamic debt instruments
like sukuks in the financial system.
(3) The distribution to the owner of a debt instrument
contributed by the owner, and the transfer to the owner of one debt instrument
in exchange for another, are prohibited transactions if within 180 days of receiving the debt instrument
the owner realizes a gain on the disposition of the instrument to any person regardless of whether the realized gain is recognized.
For example, while a highly-rated "Class 1" debt instrument
or preferred stock requires a 0.3% capital charge, a highly rated "Class 1" common stock requires a capital charge of 30%, or 100 times higher than that of debt or preferred stock under NAIC risk-based capital guidelines.
Another concern is that the debt instrument
of the acquired company might have a change of control provision where there are prepayment penalties.
The Capital Market Authority (CMA) said that a single qualified foreign investor (QFI) would be allowed to hold as much as 10 percent of shares in a company or debt instrument
. In aggregate, foreign investors will be allowed to hold up to 49 percent of shares or debt, according to the CMA document .
Cancellation-of-debt (COD) income can arise from the modification of an existing debt instrument
. Practitioners should be familiar with the COD rules to ensure that modifications of a limited liability company's (LLC's) debts are not significant enough to cause the members to recognize COD income.
"The specific benefits of debt instrument
to the issuer is the ability to raise fund for the long term project without dilution of company's equity ownership structure.
. The proposed regulations define "debt instrument
" broadly but exclude debt instruments
described in Sec.
BANKING AND CREDIT NEWS-December 23, 2011--CARE rates CIFCL's debt instrument
at A+(C)2011 M2 COMMUNICATIONS http://www.m2.com
To defeat the tax agency's argument that the structure is merely a tax gimmick without substance and that the debt owed by Target to Holding should be disregarded, Target and Holding must be able to demonstrate that the debt had the form of a debt instrument
, that the parties intended that it be a debt instrument
, and that economically the instrument was a debt.