Examples of Contingent Payment Regulations in a sentence
Even if the Contingent Payment Regulations do not apply to the notes, other alternative U.S. federal income tax characterizations of the notes are possible which, if applied, also could affect the timing and the character of a U.S. Holder’s income or loss.
Also, if the IRS were successful in asserting that the Notes were subject to the Contingent Payment Regulations, the timing and character of income thereon would be affected.
Under the Contingent Payment Regulations, Acterna LLC must construct a projected payment schedule for the New Secured Term Notes and holders generally must recognize all interest income with respect to a note on a constant yield basis based on this projected payment schedule, subject to certain adjustments if actual contingent payments differ from those projected.
In addition, the Notes should not constitute contingent payment debt instruments that would be subject to the Treasury regulations governing contingent payment obligations (the "Contingent Payment Regulations").
For United States federal income tax purposes, a holder must use the comparable yield and projected payment schedule in determining the amount and accrual of OID, unless the holder explicitly discloses in accordance with the Contingent Payment Regulations its differing position.