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Get Contingent Convertible Debt InstrumentsBRequest For Comments

Uidance on the tax treatment of a debt instrument that is convertible into stock of the issuer and that also provides for one or more contingent cash payments (contingent convertible debt instruments). The revenue ruling holds that, in the described circumstances, the noncontingent bond method described in ' 1.1275-4(b) of the Income Tax Regulations applies to these debt instruments. In addition, the revenue ruling addresses how an issuer determines the comparable yield used to determine the int.

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