Debt Instruments with Original Issue Discount; Anti-Abuse Rule

Resumo

This document contains 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 this temporary regulation also serves as the text of the proposed regulation set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register.