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TREAS/IRS | RIN: 1545-BN85 | Publication ID: Fall 2024 |
Title: Limitation on Bond Repurchase Premium Deduction on Convertible Debt | |
Abstract:
The proposed regulations will revise the guidance under section 249 of the Internal Revenue Code relating to the limitation on the deduction for bond repurchase premium on convertible debt. For example, to reduce controversies between taxpayers and the IRS, the proposed regulations will revise the existing guidance to provide clearer standards to determine the amount of any bond repurchase premium that is deductible by the issuer. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1.249-1 | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 249 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-127325-15 (NPRM) Drafter attorney: Kilsy Barnes (202) 317-6945 Reviewer attorney: William E. Blanchard (202) 317-3900 Treasury attorney: N/A CC: FIP | |
Regulatory Flexibility Analysis Required: Undetermined | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Kilsy Barnes Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW, Room 3547, Washington, DC 20224 Phone:202 317-6945 Fax:855 574-9025 Email: kilsy.t.barnes@irscounsel.treas.gov |