Assertion: debt instrument | /r/HasProperty | issued on a testing date
Facets:
value: by the covered member
type: OTHER
Source sentences:
text: Specified portion: With respect to a debt instrument issued by a controlled partnership and a covered member that is an expanded group partner, the portion of the debt instrument that is treated as issued on a testing date by the covered member and that, absent the required recharacterization with respect to a debt instrument issued by a controlled partnership, would be treated as stock on the testing date.
text: The term specified portion means, with respect to a debt instrument issued by a controlled partnership and a covered member that is an expanded group partner, the portion of the debt instrument that is treated under paragraph (f)(3)(i) of this section as issued on a testing date (within the meaning of paragraph (f)(3)(ii) of this section) by the covered member and that, absent the application of paragraph (f)(4)(i) of this section, would be treated as stock under § 1.385-3(b)(2) or (b)(3)(i) on the testing date.