Assertion: debt instrument's interest | /r/HasProperty | treated as stock
Facets:
value: under this paragraph
type: TEMPORAL
value: depending on the relevant facts
type: OTHER
Source sentences:
text: This section sets forth factors that control the determination of whether an interest is treated as stock or indebtedness.
text: If a member of an expanded group enters into a transaction with a principal purpose of avoiding the purposes of this section or § 1.385-3, an interest issued or held by that member or another member of the member's expanded group may, depending on the relevant facts and circumstances, be treated as stock.
text: Paragraphs (b)(4)(i) and (ii) of this section include a non-exhaustive list of transactions that could result in an interest being treated as stock under this paragraph (b)(4).
text: An interest is treated as stock if it is issued with a principal purpose of avoiding the purposes of this section or § 1.385-3.