Part I. Rulings and Decisions Under the Internal Revenue Code of 1986.

The article discusses the final regulations related to the modification of debt instruments by the U.S. Internal Revenue Service (IRS). It states that the regulations are clarifying the extent to which the deterioration in the financial condition of the issuer is taken to account. The regulations also determine if a modified debt instrument will be recharacterized as an instrument or property right that is not debt, and provide guidance to issuers and holders of debt instruments.