Assertion: debt instrument's payment | /r/HasProperty | contingent
Facets:
value: within the meaning of §
type: OTHER
value: on the taco stand’s profits
type: TRANSITIVE-OBJECT
value: within the meaning of reg
type: OTHER
value: like the second instrument
type: OTHER
value: as in an ownership stake
type: OTHER
value: as to time
type: TEMPORAL
Source sentences:
text: This paragraph (b)(9)(iii) provides rules for debt instruments that have payments that are contingent as to time.
text: Except as provided in paragraph (a)(2) of this section, this section applies to any debt instrument that provides for one or more contingent payments.
text: The debt instrument is a contingent payment or inflation-indexed debt instrument.
text: In general, a contingent payment debt instrument provides for one or more payments that are contingent as to timing or amount.
text: Parallel to the first instrument, Jane will receive a fixed sum on a fixed date (as in a loan), but like the second instrument, payment of the sum is contingent on the taco stand’s profits (as in an ownership stake).
text: To determine the amount of interest (OID) that is deductible each year on a debt instrument that provides for contingent payments, see § 1.1275-4.
text: Additionally, a VRDI generally may not provide for any principal payments that are contingent within the meaning of Reg.
text: If a debt instrument contains a contingent payment based on market information (defined as any information on which an objective rate can be based under the variable rate debt instrument regulations [ see Reg.
text: For example, if this paragraph (g) applies to a debt instrument that provides for a contingent payment, the Commissioner can treat the contingency as if it were a separate position.
text: C, a foreign corporation not subject to U.S. taxation, issues to a U.S. holder a debt instrument that provides for a contingent payment.
text: Except as provided in paragraph (a)(2) of this section, the debt instrument must not provide for any principal payments that are contingent (within the meaning of § 1.1275-4(a)).
text: Notwithstanding paragraph (b) of this section, if a debt instrument subject to section 1274 provides for one or more contingent payments, the issue price of the debt instrument is the lesser of the instrument's noncontingent principal payments and the sum of the present values of the noncontingent payments (as determined under paragraph (c) of this section).
text: For additional rules relating to a debt instrument that provides for one or more contingent payments, see § 1.1275-4.
text: In general, any debt instrument that provides for one or more contingent payments is a CPDI and subject to the contingent payment debt regulations in Reg.