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AHYDO |
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? References in periodicals archive |
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For a DI to trigger the AHYDO provisions, the following conditions
must be met: (1) the issuer must be a corporation for Federal tax
purposes (but not an S corporation) (Sec. While no regulations have been issued under that
provision, in January 1995 Treasury finalized partnership anti-abuse
regulations, which contain an example addressing an AHYDO issued by a
partnership; see Regs. In the case of an AHYDO issued by a
corporation, no deduction is allowed for the disqualified portion of OID
on such obligation and the remainder of the OID is not deductible until
paid. |
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