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1 26 CFR § 1.163-4 - Deduction for original issue discount on ...
https://www.law.cornell.edu/cfr/text/26/1.163-4
A deduction for an otherwise deductible portion of original issue discount with respect to a debt instrument will not be allowable as a deduction to the issuer ...
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2 Publication 1212 (01/2022), Guide to Original Issue Discount ...
https://www.irs.gov/publications/p1212
An OID debt instrument generally has market discount if your adjusted basis in the debt instrument immediately after you acquired it (usually its purchase price) ...
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3 Original Issue Discount (OID) Deducted as Interest
https://answerconnect.cch.com/document/arp106d098fee7c571000847590b11c18c9020a1/federal/irc/explanation/original-issue-discount-oid-deducted-as-interest
Debt instruments with original issue discount, however, are issued at prices below the redemption price, and the return is in the form of appreciation in price.
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4 Original Issue Discount (OID) Form 1099-OID | H&R Block
https://www.hrblock.com/tax-center/irs/forms/original-issue-discount-oid/
Original issue discount (OID) is a form of interest. It usually occurs when companies issue bonds at a price less than their redemption value at maturity.
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5 Original Issue Discount (OID): Formula, Uses, and Examples
https://www.investopedia.com/terms/o/oid.asp
An original issue discount (OID) is the amount of discount or the difference between the original face value and the price paid for the bond.
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6 Form 1099-OID - Original Issue Discount – Support
https://support.taxslayerpro.com/hc/en-us/articles/360009173314-Form-1099-OID-Original-Issue-Discount
Original Issue Discount (OID) is the difference between the face amount of a debt instrument (typically a bond) and the price that an investor ...
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7 Introduction to Original Issue Discount
https://files.klgates.com/webfiles/Introduction_to_Original_Issue_Discount.pdf
payers want to deduct interest expenses ASAP recipients prefer to defer taxable income ... “Original Issue Discount” = unstated interest.
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8 Original Issue Discount
https://www.wsc.com/portal/hps/oid_tutorial.html
A long-term debt instrument generally has Original Issue Discount (OID) when it is issued for a price less than its stated redemption price at maturity ( ...
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9 26 CFR 1.163-12 -- Deduction of original issue discount on ...
https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc4930337f38ecfd/section-1.163-12
For purposes of this section, original issue discount is an amount described in section 1273, whether from sources inside or outside the United States. (2) ...
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10 Original Issue Discount (OID) | Practical Law - Westlaw
https://content.next.westlaw.com/practical-law/document/I03f4d70beee311e28578f7ccc38dcbee/Original-Issue-Discount-OID?viewType=FullText&transitionType=Default&contextData=(sc.Default)
Original Issue Discount (OID) ... The discount from the face value of a bond or other debt instrument at the time that it is issued. Under relevant ...
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11 26 CFR 1.163-12 - Content Details - GovInfo
https://www.govinfo.gov/app/details/CFR-1999-title26-vol2/CFR-1999-title26-vol2-sec1-163-12
Section 1.163-12 - Deduction of original issue discount on instrument held by related foreign person. Date. April 1, 1999. Citation Text.
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12 What is Form 1099-OID? - TurboTax Tax Tips & Videos
https://turbotax.intuit.com/tax-tips/irs-tax-forms/what-is-form-1099-oid/L5kJapPr0
Form 1099-OID, Original Issue Discount, exists to report income when bonds, notes, or certificates of deposit (CDs) are sold at a discount ...
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13 Original Issue Discount Do Not Cut or Separate Forms on This ...
https://www.tax.ny.gov/pdf/pit/irs-docs/2019/pit/other-forms/form-1099-oid.pdf
Form 1099-OID. 2019. Cat. No. 14421R. Original Issue. Discount ... Instructions for Form 1040 to see where to take the deduction.
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14 26 USC 163: Interest - U.S. Code
https://uscode.house.gov/quicksearch/get.plx?title=26§ion=163
The portion of the original issue discount with respect to any debt instrument which is allowable as a deduction to the issuer for any taxable year shall be ...
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15 Original Issue Discount Debt (OID) on Bonds - Full Tutorial
https://breakingintowallstreet.com/kb/debt-equity/original-issue-discount-debt/
Original Issue Discount (OID): This occurs when the Face Value of a bond is $100, but the company issues it for some amount less than $100, such as $90, because ...
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16 Interest - PA Department of Revenue
https://www.revenue.pa.gov/FormsandPublications/PAPersonalIncomeTaxGuide/Pages/Interest.aspx
The remaining portion of the discount is treated as original issue discount with respect to an obligation that is not tax-exempt and as imputed interest.
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17 Original Issue Discount: Definition & Taxation - Study.com
https://study.com/academy/lesson/original-issue-discount-definition-taxation.html
› ... › Timing in Taxation
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18 Amending a Debt Instrument Trading at a Discount
https://www.skadden.com/insights/publications/2020/05/amending-a-debt-instrument-trading-at-a-discount
Perhaps even more surprising is that often the discount inherent in the new debt instrument creates deductions for original issue discount ...
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19 Original Issue Discount Sample Clauses - Law Insider
https://www.lawinsider.com/clause/original-issue-discount
Original Issue Discount. ... Such information shall include the amount of original issue discount includible in income for each authorized minimum denomination of ...
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20 IRC Code Section 1273 (Original Issue Discount Tax Treatment)
https://www.taxnotes.com/research/federal/usc26/1273
Access full-texts of the IRC on Tax Notes, with itemized details on Code Section 1273—determining the amount of original issue discount (OID) tax treatment.
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21 500DM - Marylandtaxes.gov
https://www.marylandtaxes.gov/forms/16_forms/500DM.pdf
Federal Section 179 depreciation deductions taken for a tax year beginning ... Deferral of deduction for original issue discount in debt for debt exchanges ...
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22 Tax Treatment of Premium and Discount Bonds
http://www.bairdfinancialadvisor.com/thepopovichfinancialgroup/mediahandler/media/16653/Tax%20Treatment%20of%20Prepium%20and%20Discount%20Bonds%20RU1.pdf
Tax-Exempt Bonds. Because the interest on municipal bonds is exempt from federal income taxes, the accretion to par for original issue discount bonds is not ...
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23 Sec. 163. Interest - Internal Revenue Code
https://irc.bloombergtax.com/public/uscode/doc/irc/section_163
The portion of the original issue discount with respect to any debt instrument which is allowable as a deduction to the issuer for any taxable year shall be ...
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24 NEW YORK STATE BAR ASSOCIATION TAX SECTION ...
https://www.sullcrom.com/siteFiles/Publications/Hochberg-Klein-NYSBA-Tax-Section-Report-05-2010.pdf
deduction of original issue discount (“OID”) that accrues on certain debt instruments. The OID regulations were issued in 19943 (other than the contingent ...
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25 Revenue Administrative Bulletin 1988-45 - State of Michigan
https://www.michigan.gov/treasury/reference/rab/content/1988/revenue-administrative-bulletin-1988-45
Original issue discount is defined in IRC Section 1273 as ". . . the excess (if any) of the stated redemption price at maturity, over the issue price." If the ...
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26 Internal Revenue Service (IRS - Treasury Department
https://home.treasury.gov/system/files/136/archive-documents/reg10667904.pdf
deduction attributable to an interest-only regular interest in a ... 1275 (relating to original issue discount (OID)) if the.
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27 Original Issue Discount + 2220 Copy B - IDMS Account Ability
https://www.idmsinc.com/PDF/1099OID.pdf
Note: This amount is not deductible. Box 10. For a taxable covered security, including a Treasury inflation-protected security, shows the amount of premium ...
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28 Tax Treatment of Bond Premium and Discount - Amazon S3
https://s3.amazonaws.com/static.contentres.com/media/documents/990086a6-d87e-46df-bdb4-681554969ee5.pdf
Buying bonds above or below par value creates a variety of tax issues ... Original Issue Discount (OID) – If a bond is issued at a price that is less than ...
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29 Tax: Interest Income: Original Issue Discount
https://ibkr.info/node/900
Original issue discount (OID) is a form of interest on a debt instrument such as a bond or note issued at less than its face amount.
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30 Sec. 163(j) final regs. address the classification of lender fees
https://www.thetaxadviser.com/issues/2021/feb/Sec-163j-classification-lender-fees.html
One form of interest is original issue discount (OID). ... $95 issue price). OID is interest expense to the borrower deductible under Sec.
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31 What is Form 1099-OID? - TaxSlayer Support
https://support.taxslayer.com/hc/en-us/articles/360015702192-What-is-Form-1099-OID-
OID stands for "original issue discount". OID arises when a bond is issued for a price less than its face value or principal amount.
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32 Form 1099-OID – Original Issue Discount
http://support.keystonetaxsolutions.com/knowledge-base/form-1099-oid-original-issue-discount/
Original Issue Discount (OID) is the difference between the face amount of a debt instrument (typically a bond) and the price that an ...
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33 Original Issue Discount (OID) - Macabacus
https://macabacus.com/terms/original-issue-discount
Original issue discount ("OID") is a form of interest equal to the excess of a debt instrument's stated redemption price at maturity over its issue price.
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34 Arizona Form 165 Sch. K-1(NR)
https://azdor.gov/file/1000/download?token=eAxEYyEO
15 Deferred amount of original issue discount deduction included in federal income in the current year under IRC Section 108(i).
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35 Original Issue Deep Discount Bonds
https://www.newyorkfed.org/medialibrary/media/research/quarterly_review/1981v6/v6n4article4.pdf
inal issue discount bonds are "deductible as interest and shall be prorated or amortized over the life of the obligation". With a straight-line prorating ...
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36 Original Issue Discount (I.R.C. §§ 1273 and 163(e))
https://taxassociate.wordpress.com/2014/06/07/original-issue-discount-i-r-c-%C2%A7%C2%A7-1273-and-163e/
The holder of a debt instrument that is issued with original issue discount (OID) must include part of the OID in gross income in each ...
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37 2022 Tax Reporting Statement Instructions - My Brokerage Info
https://www.mybrokerageinfo.com/app/proxy/content?literatureURL=/749895.PDF
deduction under section 199A. ... a deduction or a credit on Form 1040 or 1040-SR. ... Guide to Original Issue Discount (OID) Instruments, for more details.
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38 Outline - NYU Law
https://www.law.nyu.edu/sites/default/files/upload_documents/Cunningham_s04.doc
Taxable Income = gross income (§61) – permitted deductions; Individuals have two groups ... Current inclusion in income of original issue discount [§1272].
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39 OVERVIEW OF THE TAX TREATMENT OF CORPORATE ...
https://www.jct.gov/CMSPages/GetFile.aspx?guid=63c0454d-af37-41a5-b894-c8fdff8ab612
For all taxpayers, if an obligation is issued with original issue discount. (“OID”), a deduction for interest is allowable over the life of ...
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40 Original Issue Discount Bonds - CostBasis.com
https://www.costbasis.com/bonds/oidbonds.html
A bond is classified as OID for "original issue discount" if the price at issuance is less than par value by more than the margin allowed by the tax code.
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41 What is the purpose of the original issue discount tax provision?
https://www.quora.com/What-is-the-purpose-of-the-original-issue-discount-tax-provision
The short answer is that this is all about the timing of receipt of income and the timing of the tax payable on that income. The purpose of Original Issue ...
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42 Computation of Net Income - NCDOR
https://www.ncdor.gov/media/1631/open
(6) Net operating loss deducted on the Federal return. ... deduction under section 163(e)(5)(F) of the code for an original issue discount on an applicable.
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43 Accretion and amortization | Taxes | Achievable Series 7
https://app.achievable.me/study/finra-series-7/learn/taxes-accretion-and-amortization
Municipal bond rules · Original issue discounts are not taxable · Secondary market discounts are taxable · Premiums do not reduce annual taxable interest · Capital ...
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44 Debt Exchanges - Cadwalader
https://www.cadwalader.com/uploads/books/3c14b084290da3a63132c506c5cb2bba.pdf
subject to the original issue discount (“OID”) rules. Finally, the ... deduction for interest paid on equity-flavored debt held by foreign.
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45 The Taxation of Distressed Debt Investments: Taking Stock
https://www.wlrk.com/webdocs/wlrknew/AttorneyPubs/WLRK.21487.10.pdf
an interest deduction is not appropriate," while leaving the tax ... rules.16 Those rules emulate, for the holder, the original issue discount (OlD).
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46 9.3 Tax accounting—debt instruments - Viewpoint - PwC
https://viewpoint.pwc.com/dt/us/en/pwc/accounting_guides/income_taxes/income_taxes__16_US/chapter_9_income_tax_US/93_debt_instruments_US.html
The terms “discount” and “premium” are defined in the context of a borrower's original issuance of a debt instrument as “original issue discount ...
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47 What Tax Consequences Should Startups and Investors Be ...
https://www.dwt.com/blogs/startup-law-blog/2020/07/what-tax-consequences-convertible-notes
In this situation, the note is said to have “original issue discount” or “OID,” which is required to be taken into income over the term of ...
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48 IRC Section 163(h)(3)(B) - Bradford Tax Institute
https://www.bradfordtaxinstitute.com/endnotes/irc_section_163h3b.pdf
There shall be allowed as a deduction all interest paid or accrued within the taxable ... For provision relating to deduction of original issue discount on ...
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49 Original Issue Discount Series E and EE bonds - YouTube
https://www.youtube.com/watch?v=1bLgYEl6OE4
Farhat Lectures. The # 1 CPA & Accounting Courses
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50 58.1-301. Conformity to Internal Revenue Code - Virginia Law
https://law.lis.virginia.gov/vacodeupdates/title58.1/section58.1-301/
The original issue discount on applicable high yield discount obligations under ... on itemized deductions under § 68(f) of the Internal Revenue Code;.
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51 Tax 3.01(3)(c)2. - Wisconsin Legislature
https://docs.legis.wisconsin.gov/document/administrativecode/Tax%203.01(3)(c)2.
Income Taxation, Deductions From Gross Income, Exclusions And Exemptions. ... accrued, or incurred $3,000 of original issue discount to B. Taxpayer C and ...
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52 Stimulus Act Enhances Flexibility in Debt Restructuring by ...
https://www.mcguirewoods.com/Client-Resources/Alerts/2009/3/Stimulus-Act-Enhances-Flexibility-in-Debt-Restructuring-by-Temporarily-Suspending-the-AHYDO-Rules
Issuers are generally entitled to deduct (and, similarly, holders are required to include as income) “original issue discount” (“OID”) on an ...
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53 Private Equity Alert - Weil, Gotshal & Manges LLP
https://www.weil.com/~/media/files/pdfs/Private_Equity_Alert_Feb_2009_Special_Edition.pdf
certain limitations on deductions of original issue discount (“OID”). The following is a brief summary of these new rules. Deferral of COD Income.
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54 ORIGINAL ISSUE DISCOUNT AND THE FOREIGN ... - jstor
https://www.jstor.org/stable/20768454
The tax treatment of original issue discount income earned by foreign ... the separation of exempt discount income from taxable gain or deductible.
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55 Debt Refinancing Transactions | Tax Issues and Opportunities
https://www.bdo.com/insights/tax/federal-tax/debt-refinancing-transactions-tax-issues-and-oppor
Debt Refinancing Transactions - Tax Issues And Opportunities ... the ability to write-off any unamortized debt issuance costs and original issue discount, ...
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56 It's About Time: Taxation of Delayed Draw Term Loans
https://www.lw.com/en/insights/2022/02/about-time-taxation-delayed-draw-term-loans
of the tranche and simplify original issue discount. (“OID”)6 tax reporting. ... line of credit are not OID, but instead are deductible under Code Sec.
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57 M&A Tax Talk - US Debt Modification Tax Rules - Deloitte
https://www2.deloitte.com/content/dam/Deloitte/us/Documents/Tax/us-tax-m&a-tax-talk-debt-modification-tax-rules-us.pdf
an offsetting amount of original issue discount. (OID) (in the future). The OID is generally treated as deductible interest expense, but.
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58 Section 1.108(i)-1 - Casetext
https://casetext.com/regulation/code-of-federal-regulations/title-26-internal-revenue/chapter-i-internal-revenue-service-department-of-the-treasury/subchapter-a-income-tax/part-1-income-taxes/computation-of-taxable-income/items-specifically-excluded-from-gross-income/section-1108i-1-deferred-discharge-of-indebtedness-income-and-deferred-original-issue-discount-deductions-of-c-corporations
Section 1.108(i)-1 - Deferred discharge of indebtedness income and deferred original issue discount deductions of C corporations (a)Overview.
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59 Tax Ohio Helpfiles > ifilehelp > help > 2017 > 1040schaadd
https://tax.ohio.gov/static/helpfiles/ifilehelp/help/2017/1040schaadd.html
Also include the amortized portion of the original issue discount on such ... those taxes were deducted in arriving at your federal adjusted gross income.
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60 12C-1.013 Adjusted Federal Income Defined.
https://floridarevenue.com/rules/pdf/12C-1.013_finaltext_eff_12122019.pdf
deductions provided for net operating losses, capital losses, ... The deferral of the deduction for original issue discount in debt for debt exchanges ...
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61 Case 8:11-cv-00965-VMC-TBM Document 1 Filed 05/03/11 ...
https://www.justice.gov/archive/tax/Boone_Complaint.pdf
Another information return is Form 1099-OID, which is used to report original issue discount (“OID”) income and any federal income tax withheld from that ...
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62 Guidance Under Section 2053 Regarding Deduction for ...
https://www.federalregister.gov/documents/2022/06/28/2022-13706/guidance-under-section-2053-regarding-deduction-for-interest-expense-and-amounts-paid-under-a
The 2009 Final Regulations generally limit the deduction for claims and ... interest (including original issue discount as determined under ...
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63 Taxation of Bond Income - thisMatter.com
https://thismatter.com/money/bonds/bond-income-taxation.htm
Imputed interest of more than $10 earned from securities should be reported by the broker or issuer on Form 1099-OID, Original Issue Discount.
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64 Federal and Tri-State Area Income Tax Treatment of ...
http://www.nysscpa.org/news/publications/the-tax-stringer/stringer-article-for-authors/federal-and-tri-state-area-income-tax-treatment-of-amortizable-bond-premium
... at a discount generating “original issue discount” – a topic for another ... IRC § 171(a)(2) disallows a deduction for tax-exempt bonds.
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65 A Field Guide to Cancellation of Debt Income
https://scholarship.law.ufl.edu/cgi/viewcontent.cgi?article=1633&context=facultypub
the creditor most often claims a bad-debt deduction or business-related loss, ... original issue discount rules, if the original debt instrument is traded ...
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66 Report No. 1366 - New York State Bar Association
https://nysba.org/Sections/Tax/Tax_Section_Reports/Tax_Reports_2017/Tax_Report_1366.html
cases deny the ability to take deductions of accrued original issue discount. (“OID”) for issuers of certain high-yield debt instruments ...
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67 Proposed Regulations on the Interest Deduction Limitation ...
https://www.gtlaw.com/en/insights/2018/12/proposed-regulations-on-the-interest-deduction-limitation-under-section
... or accrued on conventional debt instruments (including original issue discount (OID), accrued market discount that is includible in the ...
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68 DOR Addback of Related Entity Expenses
https://www.revenue.wi.gov/Pages/FAQS/ise-crpaddbk.aspx
All interest paid or accrued within the taxable year on indebtedness. · Original issue discount. · Nonseparately stated interest included in carrying charges for ...
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69 Tax Treatment of Convertible Debt and SAFEs - Withum
https://www.withum.com/resources/tax-treatment-convertible-debt-and-safes/
Even though the conversion feature itself does not create original issue discount (OID), there can still be OID if a convertible debt is ...
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70 Income Tax Federal Tax Changes
https://dor.georgia.gov/rules-policies/income-tax/income-tax-federal-tax-changes
For 2021, Georgia has adopted the increased I.R.C. Section 179 deduction of ... Modified rules for high yield original issue discount obligations, ...
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71 26 U.S.C. § 163 - U.S. Code Title 26. Internal Revenue Code ...
https://codes.findlaw.com/us/title-26-internal-revenue-code/26-usc-sect-163
There shall be allowed as a deduction all interest paid or accrued within the taxable ... For provision relating to deduction of original issue discount on ...
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72 17.0 MISCELLANEOUS - Franchise Tax Board
https://www.ftb.ca.gov/tax-pros/procedures/s-corp-handbook/s-corp-chapter-17.pdf
A 2-percent shareholder may be allowed to deduct a health insurance premium on ... This excess is treated as original issue discount (OID) under Code Sec.
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73 COVID-19: Limitations on Interest Deductibility Before and ...
https://www.jdsupra.com/legalnews/covid-19-limitations-on-interest-51681/
Prior to the TCJA, taxpayers were generally entitled to deduct business ... [14] and (4) that has “significant original issue discount.
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74 2019-1099-tax-form-user-manual.pdf - LPL Financial
https://www.lpl.com/content/dam/lpl-www/documents/disclosures/2019-1099-tax-form-user-manual.pdf
For accounts holding original issue discount (OID), widely ... accrued during the year as a foreign tax credit or as an itemized deduction.
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75 Tackle Tax Issues of Restructuring Distressed Debt and ...
https://www.troutman.com/images/content/2/7/272079/Tackle-Tax-Issues-of-Restructuring-Distressed-Debt-and-Businesse.pdf
Debt issued with original issue discount (“OID”) ... Interest accrued but not collected is “reversed” by way of deduction, not.
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76 Key Federal Income Tax Considerations in Corporate Debt ...
https://www.kirkland.com/siteFiles/kirkexp/publications/2530/Document1/Key%20Federal.pdf
Unpaid Interest or Original. Issue Discount (OID). An issuer that uses the cash method of accounting generally is entitled to deduct interest when paid, ...
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77 PRESENT LAW AND BACKGROUND RELATING TO TAX ...
https://www.finance.senate.gov/download/2011/07/13/witness-testimony-1
F. Rules to Match Timing of Tax Deduction and Income Inclusion Relating ... may be deemed to be issued with original issue discount (to the ...
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78 Tax Issues in Bankruptcy and Insolvency Restructurings
https://www.lataxattorney.com/tax-issues-in-bankruptcy-and-insolvency-restructurings.html
Original issue discount (OID) can also arise on the exchange of old debt for new debt. Generally, OID is the excess of stated redemption price at maturity over ...
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79 105-130.5. Adjustments to federal taxable income in ...
https://www4.ncleg.net/enactedlegislation/statutes/html/bysection/chapter_105/gs_105-130.5.html
(22) The amount allowed as a deduction under section 163(e)(5)(F) of the Code for an original issue discount on an applicable high yield discount obligation ...
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80 Income to Be Reported on the Alabama Income Tax Return
https://www.revenue.alabama.gov/individual-corporate/income-to-be-reported-on-the-alabama-income-tax-return/
Original Issue Discount. Distributions from an Individual ... Refunds of federal income tax if deducted in a prior year and resulted in a tax benefit.
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81 New York City Bar Association
https://www.nycbar.org/pdf/report/ABCNY%20CityBar_%20Distressed_debt.pdf
The second aspect concerns the treatment of original issue discount ... Under the accrual method of accounting, an expense is deductible in ...
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82 Interest and adjusted taxable income - KPMG United States
https://home.kpmg/us/en/home/insights/2020/08/tnf-section-163j-interest-and-adjusted-taxable-income.html
... treated as interest (compensation for use or forbearance of money) under the Code or regulations, such as stated interest and original issue discount.
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83 Legal Alert: IRS Proposed Regulations Make Registered Form ...
https://us.eversheds-sutherland.com/NewsCommentary/Legal-Alerts/204034/Legal-Alert-IRS-Proposed-Regulations-Make-Registered-Form-Determination-for-Bonds-More-Bearable
The proposed regulations also provide a cross reference to the “publicly traded” rules in the original issue discount regulations for ...
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84 Beware the Tax Consequences of the Convertible Note
https://www.angelcapitalassociation.org/blog/beware-the-tax-consequences-of-the-convertible-note/
Under IRS Section 1273(a), the annual interest accrual may be treated as “original issue discount” or “OID.” The company is obligated to ...
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85 What is ABP and why is it on my tax return? - Henry+Horne
https://www.hhcpa.com/blogs/income-tax-accountants-cpa/abp-tax-return/
This explains why it is reported on Schedule B on your Form 1040 and not anywhere else. OID. Original Issue Discount is the opposite. This means ...
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86 Original Issue Discount (OID) - Reference For Business
https://www.referenceforbusiness.com/encyclopedia/Oli-Per/Original-Issue-Discount-OID.html
Original issue discount (OID) refers to a debt instrument initially issued at a price substantially below its face amount (i.e., at a deep discount).
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87 Untangling tax reform: business interest limitation - Baker Tilly
https://www.bakertilly.com/insights/untangling-tax-reform-business-interest-limitation
The Tax Cuts and Jobs Act limits how much of deduction businesses can ... The original issue discount deferral rules, any capitalization ...
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88 Certain Tax and Regulatory Considerations in Acquisition ...
https://www.lexisnexis.com/community/insights/legal/practical-guidance-journal/b/pa/posts/certain-tax-and-regulatory-considerations-in-acquisition-financings
If the AHYDO rules are applicable, then the interest deduction for the borrower ... For more information on AHYDO issues, see Applicable High-Yield Discount ...
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89 An introduction to the federal income tax issues associated ...
https://clarknuber.com/articles/an-introduction-to-the-federal-income-tax-issues-associated-with-conversion-features/
It has appeal for start-up ventures because the cost of issuing convertible ... will be treated as original issue discount, described below.
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90 Accrued interest vs PIK interest: Important distinctions - RSM US
https://rsmus.com/insights/tax-alerts/archives/accrued-interest-vs-pik-interest-important-distinctions-exist-for-cash-and-accrual-method-taxpayers.html
PIK interest is accounted for under the original issue discount (OID) rules for inclusion into income. Under these rules, a creditor is ...
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91 Estate Planning Issues With Intra-Family Loans and Notes
https://www.naepcjournal.org/journal/issue12c.pdf
be deductible as a bona fide debt at the client's death if the note is still ... not paid annually, the original issue discount (OID) rules will probably.
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92 Taxable Income (“TI”) - Ivins, Phillips & Barker
https://www.ipbtax.com/assets/htmldocuments/ABA%20Presentation%20May%202017%20-%20Hood-Fiduciary%20Income%20Tax.pdf
Miscellaneous itemized deductions subject to ... Income Distribution Deduction (“IDD”) ... Original issue discount (“OID”) on fixed.
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93 Tax implications of bonds and bond funds - Fidelity Investments
https://www.fidelity.com/learning-center/investment-products/mutual-funds/tax-implications-bond-funds
If you bought the bond when it was issued at its original issue price and hold it ... on the size of the discount and the years to maturity of the bond.
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94 THE TAX CLUB - Dechert LLP
https://www.dechert.com/content/dam/dechert%20files/knowledge/publication/2015/5/HowCouldThisPossiblyBe.pdf
character of income or deduction, source of the income, ... original issue discount rules treat payments from borrowers to lenders as ...
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95 Taxes and Tax Shelters: Taxation of Municipal Bonds - Quizlet
https://quizlet.com/194637266/taxes-and-tax-shelters-taxation-of-municipal-bonds-flash-cards/
Original issue discount bonds must be accreted under IRS rules, with the discount being treated as municipal interest income (which is not taxed by the Federal ...
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96 TIR 09-21: Certain Personal Income Tax and Corporate ...
https://www.mass.gov/technical-information-release/tir-09-21-certain-personal-income-tax-and-corporate-excise-changes-in-the-fiscal-year-2010-budget-legislation
Generally, an issuer of a debt instrument with original issue discount (OID) may deduct OID as it accrues over time. However, under IRC § 163(e)(5), ...
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