Guidance Regarding the Treatment of Certain Contingent Payment Debt Instruments With One or More Payments That Are Denominated in, or Determined by Reference to, a Nonfunctional Currency
other · IRS · Rule · Published 2004-08-30 · Effective 2004-08-30 · 69 FR 52816
Document
Document number
04-19642
Federal Register citation
69 FR 52816
CFR reference
26 CFR 1
Type
Rule
Action
Final regulation.
Category
other
Sub-agency
IRS
Publication date
2004-08-30
Effective date
2004-08-30
Treasury docket
TD 9157
Abstract
This document contains final regulations regarding the treatment of contingent payment debt instruments for which one or more payments are denominated in, or determined by reference to, a currency other than the taxpayer's functional currency. These regulations are necessary because current regulations do not provide guidance concerning the tax treatment of such instruments. The regulations affect issuers and holders of such instruments.