Publication 1212 - List Of Original Issue Discount Instruments - Department Of Treasury - 2002 Page 11

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ments, holders and issuers must use the non-
Net positive adjustment. A net positive ad-
ing principal amount as if there were no inflation
justment exists when the total of any positive
or deflation over the term of the instrument.
contingent bond method.
adjustments described in (2) above is more than
Index ratio. This is a fraction, the numerator
the total of any negative adjustments. Treat a
Noncontingent bond method.
Under this
of which is the value of the reference index for
net positive adjustment as additional OID for the
method, the issuer must construct a hypothetical
the date and the denominator of which is the
tax year.
noncontingent bond that has terms and condi-
value of the reference index for the instrument’s
tions similar to the contingent payment debt in-
Net negative adjustment. A net negative
issue date.
strument. The issuer constructs the payment
adjustment exists when the total of any negative
A qualified reference index measures infla-
schedule of the hypothetical noncontingent
adjustments described in (2) above is more than
tion and deflation over the term of a debt instru-
bond by projecting a fixed amount for each con-
the total of any positive adjustments. Use a net
ment. Its value is reset each month to a current
tingent payment. Holders and issuers accrue
negative adjustment to offset OID on the debt
value of a single qualified inflation index (for
OID on this hypothetical noncontingent bond
instrument for the tax year. If the net negative
example, the nonseasonally adjusted U.S. City
using the constant yield method that applies to
adjustment is more than the OID on the debt
Average All Items Consumer Price Index for All
fixed payment debt instruments. When a contin-
instrument for the tax year, you can claim the
Urban Consumers (CPI-U), published by the
gent payment differs from the projected fixed
difference as an ordinary loss. However, the
Bureau of Labor Statistics of the Department of
amount, the holders and issuers make adjust-
amount you can claim as an ordinary loss is
Labor). The value of the index for any date
ments to their OID accruals. If the actual contin-
limited to the OID on the debt instrument you
between reset dates is determined through
gent payment is larger than expected, both the
included in income in prior tax years. You must
straight-line interpolation.
issuer and the holder increase their OID accru-
carry forward any net negative adjustment that
The daily index ratios for Treasury
als. If the actual contingent payment is smaller
is more than the total OID for the tax year and
than expected, holders and issuers generally
inflation-indexed securities are avail-
prior tax years and treat it as a negative adjust-
able on the Internet at www.
decrease their OID accruals.
ment in the next tax year.
publicdebt.treas.gov.
Basis adjustments. In general, increase your
Form 1099 – OID. The amount shown in box 1
basis in a contingent payment debt instrument
of the Form 1099 – OID you receive for a contin-
by the OID included in income. Your basis, how-
gent payment debt instrument may not be the
Form 1099 – OID. The amount shown in box 6
ever, is not affected by any negative or positive
correct amount to include in income. For exam-
of the Form 1099 – OID you receive for an
adjustments. Decrease your basis by any non-
ple, the amount may not be correct if the contin-
inflation-indexed debt instrument may not be the
contingent payment received and the projected
gent payment was different from the projected
correct amount to include in income. For exam-
contingent payment scheduled to be received.
amount. If the amount in box 1 is not correct, you
ple, the amount may not be correct if you bought
must figure the OID to report on your return
the debt instrument (other than at original issue)
Treatment of gain or loss on sale or ex-
under the following rules. For information on
or sold it during the year. If the amount shown in
change. If you sell a contingent payment debt
showing an OID adjustment on your tax return,
box 6 is not correct, you must figure the OID to
instrument at a gain, your gain is ordinary in-
see How To Report OID, earlier.
report on your return under the following rules.
come (interest income), even if you hold the
For information about showing an OID adjust-
instrument as a capital asset. If you sell a contin-
Figuring OID. To figure OID on a contingent
ment on your tax return, see How To Report
gent payment debt instrument at a loss, your
payment debt instrument, you need to know the
OID, earlier.
loss is an ordinary loss to the extent of your prior
“comparable yield” and “projected payment
OID accruals on the instrument. If the instrument
schedule” of the debt instrument. The issuer
Figuring OID.
Figure the OID on an
is a capital asset, treat any loss that is more than
must make these available to you.
inflation-indexed debt instrument using one of
your prior OID accruals as a capital loss.
the following methods.
Comparable yield. The comparable yield is
See section 1.1275 – 4 of the regulations for
the yield on the hypothetical noncontingent bond
exceptions to these rules.
The coupon bond method, described in
that the issuer determines and constructs at the
the following discussion, applies if the in-
Premium, acquisition premium, and market
time of issuance.
strument is issued at par, all stated inter-
discount. The rules for accruing premium, ac-
Projected payment schedule. The pro-
est payable on the instrument is qualified
quisition premium, and market discount do not
jected payment schedule is the payment sched-
stated interest, and the coupons have not
apply to a contingent payment debt instrument.
been stripped from the instrument. This
ule of the hypothetical noncontingent bond. The
See section 1.1275 – 4 of the regulations to de-
schedule includes all fixed payments due under
method generally applies, for example, to
termine how to account for these items.
Treasury inflation-indexed securities.
the contingent payment debt instrument and a
projected fixed amount for each contingent pay-
The discount bond method applies to
ment. The projected payment schedule is cre-
Inflation-Indexed Debt Instruments
any inflation-indexed debt instrument that
ated by the issuer. It is used to determine the
does not qualify for the coupon bond
holder’s interest accruals and adjustments.
This discussion shows how you figure OID on
method, such as a stripped instrument.
certain inflation-indexed debt instruments is-
Steps for figuring OID. Figure the OID on a
This method is described in section
sued after January 5, 1997. An inflation-in-
contingent payment debt instrument in two
1.1275 – 7(e) of the regulations.
dexed debt instrument is generally a debt
steps.
Under the coupon bond method, figure the OID
instrument on which the payments are adjusted
you must report for the tax year as follows.
for inflation and deflation (such as Treasury
1) Figure the OID on the hypothetical non-
inflation-indexed securities (TIIS)).
contingent bond using the constant yield
Debt instrument held at the end of the tax
In general, if you hold an inflation-indexed
method (discussed earlier under Debt In-
year. If you held the debt instrument at the end
debt instrument, you must report as OID any
struments Issued After 1984 ) that applies
of the tax year, figure your OID for the year using
increase in the inflation-adjusted principal
to fixed payment debt instruments. Use the
the following steps.
amount of the instrument that occurs while you
comparable yield as the yield to maturity.
held the instrument during the tax year. You
Use the projected payment schedule to
1) Add the inflation-adjusted principal amount
must include the OID in gross income whether or
determine the hypothetical bond’s adjusted
for the day after the last day of the tax year
not you hold the instrument as a capital asset.
issue price at the beginning of the accrual
and any principal payments you received
Your basis in the instrument is increased by the
period. Do not treat any amount payable
during the year. (For TIIS, multiply the par
OID you include in income.
as qualified stated interest.
value by the index ratio for the day after
the last day of the tax year, and add any
2) Adjust the OID in (1) to account for actual
Inflation-adjusted principal amount. For
principal payments received.)
contingent payments. If the contingent
any date, the inflation-adjusted principal amount
payment is greater than the projected fixed
of an inflation-indexed debt instrument is the
2) Subtract from (1) above the inflation-ad-
amount, you have a positive adjustment. If
instrument’s outstanding principal amount multi-
justed principal amount for the first day on
the contingent payment is less than the
plied by the index ratio for that date. (For TIIS,
which you held the instrument during the
projected fixed amount, you have a nega-
multiply the par value by the index ratio for that
tax year. (For TIIS, subtract from (1) above
tive adjustment.
date.) For this purpose, determine the outstand-
the product of the par value times the in-
Page 11

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