Debt Instruments With Original Issue Discount; Anti-Abuse Rule; Price Level Adjusted Mortgages

요약

In the rules and regulations section of this issue of the Federal Register, the IRS is issuing a temporary regulation that adds an anti-abuse rule to the final regulations relating to the tax treatment of debt instruments with original issue discount. The rule allows the Commissioner of Internal Revenue, in certain circumstances, to apply or depart from the final regulations in a manner that ensures a reasonable result in light of the purposes of the statutes governing original issue discount. The text of the temporary regulation also serves as the text of this proposed regulation. This document also withdraws the proposed regulations relating to the tax treatment of price level adjusted mortgages and the portion of the 1992 proposed regulations relating to the treatment of a debt instrument that provides for contingent payments.