Assertion: modified debt instrument | /r/CapableOf | continue to be debt
Facets:
value: for all tax purposes
type: PURPOSE
value: to the extent
type: OTHER
Source sentences:
text: What precipitated the new regulations was the apparent limitation of the rule disregarding a deterioration in the issuer’s creditworthiness only for purposes of determining whether a debt instrument has been significantly modified and not for purposes of determining whether the modified debt instrument continued to be debt for all tax purposes.
text: The preamble to the proposed regulations clarifies that any decrease in the fair market value (FMV) of a debt instrument (regardless of whether it is publicly traded or not) between the issue date of the debt instrument and the date of the modification is not taken into account for purposes of determining whether the modified debt instrument continues to be debt for all tax purposes to the extent the decrease in FMV is attributable to the deterioration in the financial condition of the issuer and not to a modification of the terms of the debt instrument.