IRS Proposes New Definition of ‘Publicly Traded’ Property for Purposes of Determining the Issue Price of a Debt Instrument

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On January 6, 2011, the Internal Revenue Service released proposed rules (REG-131947-10) under U.S. Treasury Department regulation 1.1273-2 that simplify and clarify when property is considered to be “publicly traded” for purposes of determining the issue price of a publicly traded debt instrument and the fair market value of publicly traded property received in exchange for a debt instrument.

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Published In: Tax Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Brandon Hadley, Katten Muchin Rosenman LLP | Attorney Advertising

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