Assertion: debt instrument | /r/HasProperty | treated
Facets:
value: both
type: MANNER
value: as having significant oid
type: OTHER
value: as funding a distribution
type: MANNER
value: consistently
type: DEGREE
Source sentences:
text: Congress was troubled by the nonparallel treatment of issuers and holders and wanted both parties to a debt instrument to be treated consistently.
text: A debt instrument is treated as having significant OID for this purpose if, at the end of any accrual period ending after the fifth year from the issue date, the cumulative accrual of interest and OID on the instrument exceeds the sum of the actual interest paid from the issue date until the end of that accrual period and the product of the yield to maturity and the instrument's issue price.66
text: If a change in circumstances occurs, solely for purposes of sections 1272 and 1273, the debt instrument is treated as retired and then reissued on the date of the change in circumstances for an amount equal to the instrument's adjusted issue price on that date.
text: If the terms of a debt instrument are modified to defer one or more payments, and the modification does not cause an exchange under section 1001, then, solely for purposes of sections 1272 and 1273, the debt instrument is treated as retired and then reissued on the date of the modification for an amount equal to the instrument's adjusted issue price on that date.
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: Funding rule: A debt instrument is treated as stock to the extent it is both treated as funding a distribution or acquisition and is issued by a covered member to a member of its expanded group.
text: A debt instrument may be treated as issued with the principal purpose of funding a distribution or acquisition if it is issued before or after such distribution or acquisition.29
text: The debt instrument is treated as issued by the consolidated group to the EG member, and if considered a CDI treated as stock under Regs.