§ 1.249-1T - Limitation on deduction of bond premium on repurchase (temporary).  


Latest version.
  • (a) through (e)(2)(i) [Reserved] For further guidance, see § 1.249-1(a) through (e)(2)(i).

    (ii) In determining the amount under § 1.249-1(e)(2)(i), appropriate consideration shall be given to all factors affecting the selling price or yields of comparable nonconvertible obligations. Such factors include general changes in prevailing yields of comparable obligations between the dates the convertible obligation was issued and repurchased and the amount (if any) by which the selling price of the nonconvertible obligation was affected by reason of any change in the issuing corporation's credit quality or the credit quality of the obligation during such period (determined on the basis of widely published financial information or on the basis of other relevant facts and circumstances which reflect the relative credit quality of the corporation or the comparable obligation).

    (e)(2)(iii) through (f)(2) [Reserved] For further guidance, see § 1.249-1(e)(2)(iii) through (f)(2).

    (3) Portion of repurchase premium attributable to cost of borrowing. Paragraph (e)(2)(ii) of this section applies to any repurchase of a convertible obligation occurring on or after July 6, 2011.

    (g) [Reserved] For further guidance, see § 1.249-1(g).

    (h) Expiration date. The applicability of this section expires on or before July 1, 2014.