Assertion: debt instrument's payment | /r/HasProperty | treated as distribution
Facets:
value: for taxable years
type: TEMPORAL
value: for purposes
type: PURPOSE
Source sentences:
text: In this case, any payments made with respect to the covered debt instrument (other than stated interest), including pursuant to a refinancing, a portion of which would be treated as made with respect to deemed partner stock if there would have been a deemed transfer, after the date that there would have been a deemed transfer and through the remaining portion of the transition period are treated as distributions for purposes of applying § 1.385-3(b)(3) for taxable years ending on or after January 19, 2017.