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The article discusses the advantages and disadvantages of original-issue discount (OID) bonds for issuers in a volatile economic climate. The OID has become a popular financial innovation in the capital markets as business enterprises seek to reduce the cost of raising money. The popularity of OIDs is linked to economic conditions. When interest rates are high, OIDs offer great savings to issuers over full-coupon bonds, and hold great attraction for investors. When interest rates return to lower levels, the financial benefits to issuers may decline but will not disappear.

This article mentions capital markets and discusses original-issue, deep-discount bonds. Advantages to the issuer are their high annual cash flow and low after-tax cost. Advantages for the investor are a high rate of return at maturity and high current yield. Disadvantages include: lack of acceptance in the corporate bond trade; the potential for being locked into a position when a tax rate is changing; and difficulty in the call procedure. Topics include risk and price volatility, net present value, discount amortization, and discounting cash flows.

The article focuses on the oil and gas financings with the assignment of an interest in the minerals with producing properties and the drilling, exploration, and enhanced recovery of such or other properties. Topics discussed include ability of oil and gas companies to fund such projects with current or future cash flow, higher interest rates on the oil and gas loans and application of original issue discount (OID) rules with the relationship of the fair market value.

The article discusses whether warrants can be deemed original issue discount and disallowed as unmatured interest. Topics covered include interest as the cost of borrowing money, postpetition interest, and the portion of prepaid interest that represents an original discounting of the claim. Also mentioned is the tax code characterization.

The article offers information on the announcement made by Office of Professional Responsibility of the U.S. Department of Justice, regarding the disciplinary sanctions involving attorneys, certified public accountants, enrolled agents and they are subject to the regulations governing practice before the U.S. Internal Revenue Service (IRS). It mentions that the reporting of original issue discount (OID) and acquisition premium on tax-exempt obligations.

The article discusses the comprehensibility of the Tax Law in context of linguistic theory of Austrian-British philosopher Ludwig Wittgenstein. Topics discussed include contextualization of tax terminology, debate over General Anti-Avoidance Rule and Ectopia that refers to the separation of tax law from presupposed true economic and legal realities or facts. Also mentioned is the Original Issue Discount that refers to the tax treatment of a bond.

The article focuses on a notice issued by the U.S. Department of Treasury regarding issuance of regulations related to the application of section 108(i) of the Internal Revenue Code to Partnerships and S Corporation, a corporation that makes a valid election to be taxed. It states that the section 108 (i) provides rules regarding the deferral of discharge of indebtedness income and original issue discount (OID) deductions of applicable debt instruments.

The article focuses on a notice issued by the U.S. Department of Treasury regarding final regulations of the Internal Revenue Code. It states that the regulations provide necessary guidance regarding inclusion of deferred discharge of indebtedness income and the accelerated deduction of deferred original issue discount (OID). It mentions that the regulations also provide rules applicable to all taxpayers regarding deferred OID deductions.

The article offers information on the decisions and rulings under the U.S. Internal Revenue Code of 1986. It explores financial regulations on tax treatment of noncompensatory and partnership options. It also discusses the original issue discount (OID) provisions, issues on transfers of interests in partnership, and proposed measurements of federal tax liabilities of partners and noncompensatory option holder,

The article provides a proposed revenue procedure wherein the U.S. Internal Revenue Service (IRS) will allow a taxpayer to use a simplified method of accounting to allocate original issue discount (OID) on credit card receivables to an accrual period. The method allocates an amount of unaccrued OID which is proportional to the amount of the stated redemption price at maturity of the pool. The purpose of the method is explained.

The article examines the Section 502(b)(2) of the U.S. Bankrupty Code and the original issue discontent (POD) in a debt security. It looks into different interpretations made by courts for the Section 502(b)(2) and unmatured interest. It explores when a debt security can be recouped by an oversecured creditor. It concludes that courts should not consider the Section 502(b)(2) as a basis for OID as part of an allowed claim.

The article explores the innovative financial instruments introduced for taxation. In 1989, the U.S. Congress created a category of instruments dubbed "applicable high-yield discount obligations" (HYDOs), on which substantial tax penalties are imposed. HYDOs are popularly known as junk bonds. When HYDO status exists, the original issue discount (OID) on the bond is bifurcated into qualified and disqualified portions. The latter segment is equal to the lesser of the entire amount of OID or an amount that bears the same ratio to the bond's total return as its disqualified yield bears to its total yield. Disqualified yield, in turn, is the excess of total yield over the applicable federal rate plus 600 basis points. Although for tax purposes the conversion of a convertible debenture into the obligor's stock is not currently taxable, this rule does not apply to an exchangeable debenture conversion. The Internal Revenue Service concluded that gain or loss is recognized on such an exchange because the bonds and stock are issued by separate corporations. Thus, the investor will generate a taxable capital gain or loss on the conversion transaction. INSET: U.K PREFFERED MECHANICS.

The article focuses on the treatment of original issue discount (OID) in bankruptcy claims with emphasis on the chapter 11 case involving financial services firm Residential Capital LLC (ResCap) in the U.S. The decision of the U.S. Bankruptcy Court for the Southern District of New York about the ResCap case is highlighted. The court ruling for the "Chateauguay" case is also discussed.

The article reports on the aspect of corporate bankruptcies that is common on debt restructuring and common to a lot of financially disturbed creditors. It states that consequence of debt modification may effect in the deemed taxable exchange of the previous debt instrument replacing a newly debt instrument. It also adds that the held exchange could focus the identification of cancellation of debt (COD) income and the accumulation of original issue discount (OID).

The article discusses the proposed regulations on "publicly traded" debt instruments. It cites the rules for calculating the amount of original issue discount (OID), which is attributable to specific debt instruments. It presents the importance of the publicly traded debt rule in determining the issue price of a debt instrument that is issued in exchange for property.

Offers advice about investing in individual bonds. Lack of liquidity of most bonds; How direct ownership doesn't save investors money; Lack of independent price movement of bonds; Dependence of the bond market on interest rates; Buy bonds at original issue; Advantage of investing in bonds through an institution.

Part II. Examines S corporation liquidation, original issue discount and special property sales. Determination of the character of income, gain or loss that flows from the S corporation to its shareholders; Issue price of an installment note containing inadequate stated interest; Rule which bars the use of the installment method for a corporate sale of inventory; Situations in which the treatment to an installment note is denied to the extent attributable to the sale of property.

Examines the effects of the original issue discount (OID) regulations from the United States Internal Revenue Service on private annuities. Definition of a private annuity; Purpose of the final regulations; Resemblance of an annuity contract to a debt instrument; Effect of OID on annuitant and obligor.

Reports that in June 1996 the regulations of the original issue discount (OID) were finalized. Attempts made on the original issue discount (OID); How the Contingent Payment Debt Instruments (CPDI) were divided into major classes; Methods that applied to each class; Conclusion reached. INSET: Executive summary..

The article discusses the final and temporary regulations issued by the Internal Revenue Service for brokers to report acquisition premium, bond premium, and transactions involving debt instruments and options. The regulations reportedly includes treating certain holder elections for reporting taxpayers' adjusted basis in a debt instrument. Other topics include basis calculation elections, options on debt instruments, and elections to consider interest as original issue discount.

The article offers information on the final regulations as issued on July 2, 2103 by the Internal Revenue Service (IRS) on the application of Section 108 of IRS Code that provides guidelines to C Corporations, which refers to any corporation that comes under federal tax law. It informs that no deduction will be allowed to debt instrument issuer for original issue discount in case of issue of new instrument in exchange for applicable instrument.

The article focuses on regulations issued by the U.S. Department of Treasury and the U.S. Internal Revenue Service (IRS) on April 18, 2013 on basis reporting by brokers for transactions in debt instruments and options. It states that the regulations reflect changes in the Energy Improvement and Extension Act of 2008. It highlights taxpayer elections for bond premium affecting basis reporting. It discusses the Form 8281, an Information Return for Original Issue Discount (OID) Instruments.

The author discusses the tax treatment of junk bonds, providing information on its difference from regular bonds as they are being issued by borrowers considered a credit risk. It mentions that junk bonds are being taxed similar to regular bonds with taxable interest as ordinary income, adding that taxing junk bonds can be complicated to report when bought for less than the face value and Original Issue Discout (OID) is involved.

The article discusses the law related to interest accruals and the uncertainties associated with the tax law in the U.S. It outlines several conditions when accrual-method taxpayers may deduct interest under Regulations Section 1.461-1(a)(2). The Internal Revenue Service (IRS) released the Revenue Ruling 80.361 which allows taxpayers not to recognize interest in events for which there is doubtful collectibility exception. It states the uncertainty on whether such exception is applicable to the accrual of original issue discount (OID).

The article focuses on the Form 1042 information reporting forms related to taxation in the U.S. It notes that taxpayers need to file such forms to notify the government about payments made to nonresident individuals as well as foreign companies and foreign partnerships. It adds that Form 1042 needs to be filed by U.S. citizens who make fixed or determinable payment of annual or periodic income (FDAP), due every March 15. It discusses the taxation for obligations carrying original issue discount (OID) sold or exchanged by a foreign owner.

The article reports that real estate agent ReMax International company in Denver, Colorado has lowered the deal's original issue discount (OID) to 90. According to some market participants, the situation would continue as more deals price at low level or even lower. Meanwhile, Remax debt package which consists of a $225 million first-lien term loan and a $70 million second-lien term loan has been introduced and led by Citi company.

Discusses Letter Ruling 9538007 issued by the US Internal Revenue Service concerning tax treatment of original issue discount (OID) on debt instruments. Cases decided by the US Supreme Court settling tax issues on OIDs; Construction of doubtful collectibility exception under the law.

Focuses on the taxation of original issue discount (OID) in the United States. Treatment of OID as a subclass of interest; Enactment of the Tax Equity and Fiscal Responsibility Act of 1982; Taxpayer as holder of subordinated debentures issued with OID by a corporation under the Technical Advice Memorandum.

The article reports on the decision of private markets investing company Hamilton Lane Advisors to reverse flex the original issue discount (OID) of a 260 million dollar term loan B that it will use for debt refinancing and payment of shareholder dividend.

The article reports on the decision by Six Flags Entertainment Group to narrow the original issue discount (OID) rate on the first-lien term loan B in 2015. Topics covered include the use of the loan to refinance existing debt and fund stock buybacks, the value of the theme park operator's senior secured debt and the rating given by Moody's Investors Service for the firm and the proposed debt.

According to KDP Investment Advisors, talk on a $150 million add-on to an existing $320 million first-lien facility is Libor plus 425-450 bps with a 99-cent original issue discount. Talk on a $120 million second-lien is Libor plus 800-825 bps with an OID of 98.5-99 cents on the dollar. [ABSTRACT FROM AUTHOR]

TransFirst Holdings has shifted some borrowings to the first-lien tranche of its $1.02 billion loan package which had final terms that priced at talk on Monday. [ABSTRACT FROM AUTHOR]

The article reports that the oil and gas exploration company Energy & Exploration Partners has shifted commitments for a $775 million term loan B proposal in July 2014. It mentions that the original issue discount (OID) was revised to 98.5 cents on the dollar against 99 cent OID. According to the company, the funds will be payed a portion of the company's capital expenditures in 2014 and 2015 which totaled $79 million.

Bookrunners priced a $901.17m conduit CMBS transaction late Tuesday at tight spreads, although market activity so far in 2018 has skewed further towards single borrower, single asset transactions [ABSTRACT FROM AUTHOR]

The bank reorganisation navigated local law issues surrounding subordination and cram-downs [ABSTRACT FROM AUTHOR]

The article reports on the 560 million British pound term loan B of the 885 million British pounds all-senior loan financing backing the buy-out of food retailer Iceland by its founder and Chief Executive Malcolm Walker, with a potential original issue discount of around 98. A revolving credit facility completes the debt financing. Figure shows the Iceland's enterprise value after the buy-out. Market participants expect the deal to be an indicator of liquidity for leveraged loans in sterling.

The article reports on the decision of the arrangers of leveraged buyouts (LBOs) for MIC and Oberthur to allocate an original issue discount (OID) of 91 and 94, respectively, to their buyout loans to attract investors. It is said that the similarities between MIC and Oberthur might make investors choose between the two. The arrangers for Oberthur's loans are Barclays, Lloyds and Royal Bank of Canada, while the loans for MIC are being arranged by Goldman Sachs, Nomura and Royal Bank of Canada.