Similar rules apply to tax-exempt municipal bonds with original issue discount
with respect to the accrual of OID and adjustment of basis.
Assume that the instrument provided, at the time of its original issuance, for a market rate of interest based on the issuer's creditworthiness, the instrument was not issued with original issue discount
and its adjusted issue price is currently $200,000,000.
Specifically, the restructuring concerns the holders of BTAS' Senior Notes, Recovery Units and Original Issue Discount
Notes and various classes of subordinated debt.
of Arizona) offer eight chapters on the annual accounting system; cash receipts and disbursements method of accounting; inventory and accounting for long-term contracts; capitalization, amortization, and depreciation; interest, original issue discount
, and other time value of money issues; deferred payment sales, including private annuity transactions and self-cancelling installment notes; exceptions to the annual accounting system, including carryovers, claim of right doctrine, tax benefit rules, and the Arrowsmith principle; and changes in accounting methods and annual accounting periods.
(3)) The election affects short-term taxable corporate obligations, as well; however, in the case of corporate obligations, original issue discount
is included unless the investor chooses to include "acquisition discount" with respect to all of them.
Debt acquired in the form of an "original issue discount
" (OLD) obligation requires accrual method accounting.
The biggest disadvantage is that each annual payment Paul receives includes an ordinary income component that is economically equivalent to interest, but does not constitute interest because Original Issue Discount
rules do not apply to private annuities.
Bonds issued with "original issue discount
," such as "zero coupon bonds," yield taxable income to the bondholders with respect to the discount over the life of the bond.
Both parties should treat the foregone interest as original issue discount
, that is a loan in the amount of $90,444.33 and original issue discount
of $9,555.67 [[section]7872(b)(2)].
With the exception of municipal bonds (discussed below), it is irrelevant for tax purposes whether the discount is a market discount or an original issue discount
(OID), bonds issued at prices substantially below par.
Section 7872 generally provides that a below-market interest rate loan has an original issue discount
(OLD) equal to the present value difference between the discounted loan payments, and imputed payments at the applicable federal rate.
This Note first discusses the concept of original issue discount
and how it has typically been interpreted in the bankruptcy setting.