Treasury Regulations (26 C.F.R.)
26 CFR § 1.1286-1
Tax treatment of certain stripped bonds and stripped coupons.
# (a) De minimis OID.
If the original issue discount determined under section 1286(a) with respect to the purchase of a stripped bond or stripped coupon is less than the amount computed under subparagraphs (A) and (B) of section 1273(a)(3) and the regulations thereunder, then the amount of original issue discount with respect to that purchase (other than any tax-exempt portion thereof, determined under section 1286(d)(2)) shall be considered to be zero. For purposes of this computation, the number of complete years to maturity is measured from the date the stripped bond or stripped coupon is purchased.
# (b)
Treatment of certain stripped bonds as market discount bonds—(1) In general. By publication in the Internal Revenue Bulletin (see § 601.601(d)(2)(ii)(b) of the Statement of Procedural Rules), the Internal Revenue Service may (subject to the limitation of paragraph (b)(2) of this section) provide that certain mortgage loans that are stripped bonds are to be treated as market discount bonds under section 1278. Thus, any purchaser of such a bond is to account for any discount on the bond as market discount rather than original issue discount.
(2) Limitation. This treatment may be provided for a stripped bond only if, immediately after the most recent disposition referred to in section 1286(b)—
(i) The amount of original issue discount with respect to the stripped bond is determined under paragraph (a) of this section (concerning de minimis OID); or
(ii) The annual stated rate of interest payable on the stripped bond is no more than 100 basis points lower than the annual stated rate of interest payable on the original bond from which it and any other stripped bond or bonds and any stripped coupon or coupons were stripped.
# (c) Effective date.
This section is effective on and after August 8, 1991.
[T.D. 8463, 57 FR 61812, Dec. 29, 1992]
Source: view the official text
In this part (40 sections)
- 1.1271-0 · Original issue discount; effective date; table of contents.
- 1.1271-1 · Special rules applicable to amounts received on retirement,…
- 1.1272-1 · Current inclusion of OID in income.
- 1.1272-2 · Treatment of debt instruments purchased at a premium.
- 1.1272-3 · Election by a holder to treat all interest on a debt…
- 1.1273-1 · Definition of OID.
- 1.1273-2 · Determination of issue price and issue date.
- 1.1274-1 · Debt instruments to which section 1274 applies.
- 1.1274-2 · Issue price of debt instruments to which section 1274…
- 1.1274-3 · Potentially abusive situations defined.
- 1.1274-4 · Test rate.
- 1.1274-5 · Assumptions.
- 1.1274A-1 · Special rules for certain transactions where stated…
- 1.1275-1 · Definitions.
- 1.1275-2 · Special rules relating to debt instruments.
- 1.1275-3 · OID information reporting requirements.
- 1.1275-4 · Contingent payment debt instruments.
- 1.1275-5 · Variable rate debt instruments.
- 1.1275-6 · Integration of qualifying debt instruments.
- 1.1275-7 · Inflation-indexed debt instruments.
- 1.1286-1 · Tax treatment of certain stripped bonds and stripped coupons.
- 1.1286-2 · Stripped inflation-protected debt instruments.
- 1.1287-1 · Denial of capital gains treatment for gains on…
- 1.1288-1 · Adjustment of applicable Federal rate for tax-exempt…
- 1.1291-0 · Treatment of shareholders of certain passive foreign…
- 1.1291-1 · Taxation of U.S. persons that are shareholders of section…
- 1.1291-9 · Deemed dividend election.
- 1.1291-10 · Deemed sale election.
- 1.1293-0 · Table of contents.
- 1.1293-1 · Current taxation of income from qualified electing funds.
- 1.1294-0 · Table of contents.
- 1.1294-1T · Election to extend the time for payment of tax on…
- 1.1295-0 · Table of contents.
- 1.1295-1 · Qualified electing funds.
- 1.1295-3 · Retroactive elections.
- 1.1296-1 · Mark to market election for marketable stock.
- 1.1296-2 · Definition of marketable stock.
- 1.1297-0 · Table of contents.
- 1.1297-1 · Definition of passive foreign investment company.
- 1.1297-2 · Special rules regarding look-through subsidiaries and…