Examples of Contingent Debt Regulations in a sentence
However, the application of the Contingent Debt Regulations to instruments such as the New Senior Notes is uncertain in several respects, and no rulings have been sought from the IRS or a court with respect to any of the tax consequences discussed below.
The Issuer and by the purchase of a Note governed hereby each beneficial owner agree for U.S. federal income tax purposes, (i) to treat the Notes as indebtedness that is subject to U.S. Treasury Regulations §1.1275-4(b) governing contingent payment debt instruments (the “Contingent Debt Regulations”), and (ii) to use the Issuer’s determination of the “comparable yield” and “projected payment schedule,” within the meaning of the Contingent Debt Regulations, with respect to the Notes.
The Company agrees, and by acceptance of a beneficial ownership interest in the Securities, each beneficial holder of Securities will be deemed to have agreed, for United States federal income tax purposes, to treat the Securities as indebtedness that is subject to Section 1.1275-4 of the United States Treasury Regulations (the "Contingent Debt Regulations").
The Issuer and by purchase of a Note governed hereby each beneficial owner agree for U.S. federal income tax purposes, (i) to treat the Notes as indebtedness that is subject to U.S. Treasury Regulations §1.1275-4(b) governing contingent payment debt instruments (the “Contingent Debt Regulations”), and (ii) to use the Issuer’s determination of the “comparable yield” and “projected payment schedule,” within the meaning of the Contingent Debt Regulations, with respect to the Notes.
However, the tax treatment of the Notes is subject to various substantial uncertainties, particularly with regard to the application of the Contingent Debt Regulations, and no rulings have been sought from the IRS or a court with respect to any of the tax consequences discussed below.