Code of Federal Regulations (Last Updated: November 8, 2024) |
Title 26 - Internal Revenue |
Chapter I - Internal Revenue Service, Department of the Treasury |
SubChapter A - Income Tax |
Part 1 - Income Taxes |
Special Rules for Determining Capital Gains and Losses |
§ 1.1275-2T - Special rules relating to debt instruments (temporary).
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(a) through (c) [Reserved] For further guidance, see § 1.1275-2(a) through (c).
(d)
Special rules for Treasury securities —(1)Issue price and issue date —(i)In general. The issue price of an issue of Treasury securities is the price of the securities sold at auction. In addition, the issue date of the issue is the first settlement date of a substantial amount of the securities.(ii)
Treasury securities auctioned before November 2, 1998. For an issue of Treasury securities auctioned before November 2, 1998, the issue price of the issue is the average price of the securities sold. In addition, the issue date of the issue is the first settlement date onwhich a substantial amount of the securities in the issue is sold. (2)
Reopenings of Treasury securities— (i)Treatment of additional Treasury securities. Additional Treasury securities issued in a qualified reopening are part of the same issue as the original Treasury securities and have the same issue price and issue date as the original Treasury securities. This paragraph (d)(2) applies to qualified reopenings that occur on or after March 25, 1992.(ii)
Definitions —(A)Additional Treasury securities. Additional Treasury securities are Treasury securities with terms that are in all respects identical to the terms of the original Treasury securities.(B)
Original Treasury securities. Original Treasury securities are securities comprising any issue of outstanding Treasury securities.(C)
Qualified reopening. A qualified reopening is a reopening that occurs not more than one year after the original Treasury securities were first issued to the public. For reopenings of Treasury securities (other than Treasury Inflation-Indexed Securities) that occur prior to November 5, 1999, a qualified reopening is a reopening of Treasury securities that satisfies the preceding sentence and that was intended to alleviate an acute, protracted shortage of the original Treasury securities.