Federal Income Taxation of Debt Instruments (6th Edition), Book - Looseleaf

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06469500
Publish Date:
11/19/2010
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The definitive treatise for the many complicated issues involved with debt instruments. This comprehensive resource contains clear interpretations of the basic rules governing original issue discount and imputed interest. Now available in eBook format - download to your computer instantly.

Pages: 1368

ISBN: 9780808025795

Binding: Loose-leaf book

Volumes: One (1) volume...

Size: 6" x 9"

Offer Number: 0-6469-501

Material ID: 10035041-7777

Federal Income Taxation of Debt Instruments (6th Edition) is the definitive reference for the complicated issues involved with debt instruments. This new edition for 2011 contains clear interpretations of the basic rules governing original issue discount and imputed interest and detailed coverage of many specialized topics. The book covers virtually every aspect of the taxation of debt instruments and many related areas.

Significant changes found in the Sixth Edition include:

  • substantial revision of the discussion of distressed debt instruments
  • new material discussing debt with multiple obligors
  • coverage of the new regulations governing the deferral of COD income under Code Sec. 108(i)
  • substantial revision of the entire chapter governing withholding and information reporting, including coverage of FACTA (Fair and Accurate Credit Transactions Act)
  • updating of the discussions of consolidated return considerations, including the rules governing intercompany obligations
  • reorganization and clarification of the materials dealing with debt modifications and the consequences of debt exchanges

The 6th Edition includes an updated CD ROM containing Microsoft® Excel® spreadsheets illustrating the tables and examples found in the text of Federal Income Taxation of Debt Instruments.

Federal Income Taxation of Debt Instruments (6th Edition) is now available in an eBook format which you can download to your computer instantly.

about the author(s)

David C. Garlock is a partner in the National Tax Department of Ernst & Young in Washington, D.C., where he has practiced since 1995.

He is an expert in the taxation of financial products, including debt instruments and derivatives and, while serving as an attorney in the Treasury Department's Office of Tax Policy from 1982 to 1986, was the principal author of the 1986 proposed regulations relating to original issue discount.

Mr. Garlock was an Adjunct Professor of Law in the Graduate Tax Program at the Georgetown University Law Center from 1989 to 1990 and has lectured extensively at continuing professional education programs in his areas of expertise. He is a past chair of the ABA Tax Section Committee on Financial Transactions.

Mr. Garlock graduated cum laude from Harvard Law School in 1979 and magna cum laude in Mathematics from Harvard College in 1975.

content

Topics and Content

Chapter 1

INDEBTEDNESS AND "DEBT INSTRUMENT" DEFINED

  • ¶101 Tax Law Definitions of Indebtedness and Interest
  • ¶102 Distinguishing Indebtedness from Other Financial Instruments

Chapter 2

DETERMINING TOTAL ORIGINAL ISSUE DISCOUNT

  • ¶201 Overview
  • ¶202 Stated Redemption Price at Maturity and Qualified Stated Interest
  • ¶203 Issue Price
  • ¶204 De Minimis Rule
  • ¶205 Interest Payable in Advance

Chapter 3

IMPUTED INTEREST ON DEBT ISSUED FOR PROPERTY

  • ¶301 Overview
  • ¶302 Scope of Sections 1274 and 483
  • ¶303 Testing for Adequate Stated Interest
  • ¶304 Imputation of Interest
  • ¶305 Installment Obligations
  • ¶306 Variable Rate Debt Instruments
  • ¶307 Contingent Payments
  • ¶308 Alternative Test Rates
  • ¶309 Potentially Abusive Situations
  • ¶310 Assumptions and Modifications
  • ¶311 Nonrecourse Debt Given in Exchange for Property
  • ¶312 Personal Use Property
  • ¶313 Sales Between Related Parties
  • ¶314 Qualified Sales of Land to Family Members
  • ¶315 Convertible Obligations Issued for Property
  • ¶316 Debt Issued in Exchange for Services
  • ¶317 Does Issue Price Determine Fair Market Value?
  • ¶318 Debt Issued in Part for Cash and in Part for Nonpublicly Traded Property

Chapter 4

BELOW-MARKET AND INTERCOMPANY LOANS

  • ¶401 Introduction and Background
  • ¶402 Scope
  • ¶403 Application of Section 7872
  • ¶404 Gift Loans
  • ¶405 Compensation-Related Loans
  • ¶406 Corporation-Shareholder Loans
  • ¶407 Loans to Qualified Continuing Care Facilities
  • ¶408 Special Rules
  • ¶409 Withholding and Information Reporting
  • ¶410 The Section 482 Regulations
  • ¶411 Split-Dollar Life Insurance

Chapter 5

CURRENT INCLUSION AND DEDUCTION OF OID

  • ¶501 Overview
  • ¶502 Debt Instruments Subject to the OID Rules
  • ¶503 Accrual Period
  • ¶504 Yield to Maturity
  • ¶505 Allocation of OID to Accrual Periods; Adjusted Issue Price
  • ¶506 Daily Portions
  • ¶507 Installment Obligations Bearing OID
  • ¶508 Stepped Interest Rate Obligations
  • ¶509 Aggregation of Debt Instruments
  • ¶510 Certain Debt Instruments Subject to Contingencies
  • ¶511 Acquisition Premium
  • ¶512 Constant Yield Election
  • ¶513 Effect of OID Accruals on Basis
  • ¶514 Accruals of Interest and OID on Nonrecourse Debt
  • ¶515 Anti-Abuse Rule
  • ¶516 United States Savings Bonds

Chapter 6

INTEREST INCLUSION IN INCOME AND DEDUCTION OF INTEREST PAYMENTS

  • ¶601 Scope of Section 446 Rules
  • ¶602 Method of Determining the Accrual of Interest
  • ¶603 Allocation of Interest to Payments
  • ¶604 Prepaid Interest
  • ¶605 Payment Out of Borrowed Funds
  • ¶606 Limitations on Interest Deductions

Chapter 7

SHORT -TERM OBLIGATIONS

  • ¶701 Overview
  • ¶702 Short-Term Obligations to Which Section 1281 Applies
  • ¶703 Deferral of Interest Deductions Under Section 1282
  • ¶704 Character Rules

Chapter 8

VARIABLE RATE DEBT INSTRUMENTS

  • ¶801 Introduction
  • ¶802 Definition of "Variable Rate Debt Instrument"
  • ¶803 Caps, Floors, Governors, and Similar Restrictions
  • ¶804 Accruals of Interest and OID on a VRDI
  • ¶805 Reset Bonds
  • ¶806 Daily Portions on a VRDI
  • ¶807 Inflation-Indexed Debt Instruments

Chapter 9

CONTINGENT PAYMENT DEBT INSTRUMENTS

  • ¶901 Introduction
  • ¶902 What Are Contingent Payments?
  • ¶903 What Is a Contingent Payment Debt Instrument?
  • ¶904 Treatment of Contingent Payment Debt Instruments Issued for Cash or Publicly Traded Property—The Noncontingent Bond Method
  • ¶905 Debt Instruments Issued for Nonpublicly Traded Property
  • ¶906 Contingent Tax-Exempt Obligations
  • ¶907 Hybrid Instruments
  • ¶908 History of the Proposed Tax Treatment of Contingent Payment Debt Instruments

Chapter 10

VARIOUS SPECIAL TYPES OF DEBT INSTRUMENTS

  • ¶1001 Debt Issued Together with Property Rights
  • ¶1002 Mandatory Sinking Funds
  • ¶1003 OID Rules for Prepayable Debt Instruments
  • ¶1004 "PIK" Notes and Bonds
  • ¶1005 Debt Instruments Involving Nonfunctional Currencies

Chapter 11

MARKET DISCOUNT

  • ¶1101 Introduction
  • ¶1102 Definition of "Market Discount Bond"
  • ¶1103 Computing Accrued Market Discount
  • ¶1104 Recognition of Market Discount
  • ¶1105 Deferral of Interest Deductions Allocable to Accrued Market Discount
  • ¶1106 Special Rules
  • ¶1107 Market Discount Rules for Distressed Debt Instruments

Chapter 12

BOND PREMIUM

  • ¶1201 Introduction
  • ¶1202 Treatment of Holders—Basic Rules
  • ¶1203 Treatment of Issuers
  • ¶1204 De Minimis Premium
  • ¶1205 Callable Bonds and Other Alternative Payment Schedules
  • ¶1206 Mortgage-Backed Securities
  • ¶1207 Special Situations
  • ¶1208 Exchanged Basis Transactions

Chapter 13

SALES, EXCHANGES, RECAPITALIZATIONS AND REDEMPTIONS

  • ¶1301 Introduction
  • ¶1302 Adjusted Basis, Amount Realized, and Character Issues
  • ¶1303 Tax Consequences of Debt-For-Debt Exchanges and Debt Modifications
  • ¶1304 Debt Issued in Exchange for Stock
  • ¶1305 Redemptions
  • ¶1306 Defeasances
  • ¶1307 Debt Contributed to and Distributed from Corporations
  • ¶1308 Debt Contributed to and Distributed from Partnerships
  • ¶1309 Debt Obligations Involving Consolidated Return Group Members

Chapter 14

DEBT MODIFICATIONS

  • ¶1401 Background and Overview
  • ¶1402 Scope and Applicability of the Debt Modification Regulations
  • ¶1403 Modification
  • ¶1404 Significant Modification
  • ¶1405 Dispositions under the Installment Sale Rules

Chapter 15

CANCELLATION OF DEBT

  • ¶1501 Principles Regarding Debtor’s Income
  • ¶1502 Income Exclusions and Exceptions to Income Treatment
  • ¶1503 Special Rules for Certain Debtors
  • ¶1504 Collateral Debtor Considerations
  • ¶1505 Consolidated Group Considerations

Chapter 16

DISTRESSED DEBT INSTRUMENTS—CREDITOR ISSUES

  • ¶1601 Introduction
  • ¶1602 Inclusion of Interest and Original Issue Discount on Distressed Debt
  • ¶1603 Losses on Debt Instruments

Chapter 17

HEDGING OF DEBT INSTRUMENTS

  • ¶1701 General Principles Relating to Hedging
  • ¶1702 Hedging of Debt Instruments
  • ¶1703 Integration of Qualifying Debt Instruments
  • ¶1704 Hedged Foreign Currency Obligations

Chapter 18

COUPON STRIPPING

  • ¶1801 Introduction
  • ¶1802 Scope of Coupon Stripping Rules
  • ¶1803 Tax Treatment of Purchasers of Stripped Bonds and Coupons
  • ¶1804 Tax Treatment of the Stripper
  • ¶1805 "Relocation" of Income
  • ¶1806 Once a Strip, Always a Strip?
  • ¶1807 Special Rules for Callable Debt Instruments
  • ¶1808 "Variable Strips"
  • ¶1809 Special Rules for Tax-Exempt Obligations

Chapter 19

WITHHOLDING AND INFORMATION REPORTING

  • ¶1901 Introduction
  • ¶1902 Information Reporting
  • ¶1903 Backup Withholding
  • ¶1904 Withholding on Payments to Foreign Taxpayers
  • ¶1905 Comparison of the Present System to Prior Law
  • ¶1906 The Post-2012 Regime—The Foreign Account Tax Compliance Act
  • ¶1907 Special Considerations for OID Obligations
  • ¶1908 Information Reporting for Interest Payments Received on Mortgages and Student Loans

Chapter 20

INTERNATIONAL ISSUES

  • ¶2001 Introduction
  • ¶2002 Effect of Interest Deduction on Foreign-Source Income, Qualified
  • Production Activities Income and Other Apportionment Issues
  • ¶2003 Registration Requirements and the TEFRA D Rules
  • ¶2004 The "Earnings Stripping" Rules of Section 163(j)
  • ¶2005 U.S. Taxation of Interest Derived by Non-U.S. Persons
  • ¶2006 Interest Deduction for Non-U.S. Persons Engaged in a U.S. Trade or Business

Appendices/Tables

  • Appendix A
  • Appendix B
  • Glossary of Acronyms
  • Table of Internal Revenue Code Sections
  • Table of Statutes and Legislative History
  • Table of Treasury Regulations
  • Table of Revenue Rulings and Other IRS Releases
  • Table of Cases
  • Table of Tax Articles
  • Table of Miscellaneous Sources
  • Index

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