Assertion: covered debt instrument | /r/HasProperty | resulted in specified portion
Facets:
value: before january
type: TEMPORAL
Source sentences:
text: This paragraph (k)(2)(iv) applies when a covered debt instrument issued by a controlled partnership in a transaction described in § 1.385-3(b)(2) would have resulted in a specified portion that gives rise to a deemed transfer on a date after April 4, 2016, and on or before January 19, 2017, but there is not a deemed transfer on such date due to the application of paragraph (k)(1), (k)(2)(i), or (k)(2)(ii) of this section and § 1.385-3(j).