Assertion: debt instrument | /r/HasProperty | issued by covered member
Facets:
value: after april
type: TEMPORAL
Source sentences:
text: Covered debt instrument (CDI): A debt instrument issued by a covered member after April 4, 2016, that is not a qualified dealer debt instrument or an excluded statutory or regulatory debt instrument and is issued by a covered member that is not a regulated financial company or a regulated insurance company.
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: 1.385-3, a debt instrument will be treated as stock if it is issued by a covered member to a member of the covered member's expanded group in:
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: 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.
text: This section applies to the portion of the debt instrument treated as issued by the covered member as described in this paragraph (f)(3)(i) in the same manner as if the covered member actually issued the debt instrument to the holder-in-form, unless otherwise provided.
text: This section and § 1.385-3 apply to the portion of the debt instrument treated as issued by the covered member as described in this paragraph (f)(3)(i) in the same manner as if the covered member actually issued the debt instrument to the holder-in-form, unless otherwise provided.