CPDI Regulations definition

CPDI Regulations has the meaning provided in Section 213 hereof;
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CPDI Regulations has the meaning specified in Section 2.12.
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CPDI Regulations means the United States Treasury Regulations governing contingent payment debt instruments, including Treasury Regulation section 1.1275-4.
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Examples of CPDI Regulations in a sentence

  • The Company shall agree and, by acceptance of the Notes pursuant to the Exchange Offer, each Holder shall be deemed to agree, to (in the absence of an administrative determination or judicial ruling to the contrary), treat the Notes for U.S. federal income tax purposes as indebtedness that is subject to the Treasury regulations governing contingent payment debt instruments (the “CPDI Regulations”), and to be bound by the Company’s application of the CPDI Regulations to the Notes.

  • U.S. Holders should be aware that on June 11, 1996, the Treasury Department issued final regulations (the "CPDI Regulations") concerning the proper United States Federal income tax treatment of contingent payment debt instruments.

  • Moreover, in general, under the CPDI Regulations, any gain recognized by a U.S. Holder on the sale, exchange, or retirement of a contingent payment debt instrument will be treated as ordinary income and all or a portion of any loss realized could be treated as ordinary loss as opposed to capital loss (depending upon the circumstances).

  • Specifically, the CPDI Regulations generally require a U.S. Holder of such an instrument to include future contingent and noncontingent interest payments in income as such interest accrues based upon a projected payment schedule.

  • The Company has requested our opinion as to whether the regulations governing contingent payment debt instruments (the "CPDI Regulations") will apply to the Debentures.

  • In general, the CPDI Regulations would cause the timing and character of income, gain or loss reported on a contingent payment debt instrument to substantially differ from the timing and character of income, gain or loss reported on a contingent payment debt instrument under general principles of current United States Federal income tax law.

  • A U.S. Holder which does not use the “comparable yield” and follow the “projected payment schedule” as established by us to calculate its OID and interest income on a note must timely disclose and justify the use of other estimates to the IRS.Federal Income Taxation of the Senior Notes under the CPDI Regulations The Noncontingent Bond Method.

  • The CPDI Regulations apply to debt instruments issued on or after August 13, 1996.

  • Under the CPDI Regulations, even if we do not pay any contingent interest on the notes, a U.S. holder of a note will be required to include interest in its gross income as original issue discount for U.S. federal income tax purposes regardless of whether such holder uses the cash or accrual method of accounting for income tax purposes.


More Definitions of CPDI Regulations

CPDI Regulations has the meaning provided in Section 2.13 hereof;
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CPDI Regulations has the meaning specified in Clause 4.16.
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Related to CPDI Regulations

  • SEBI Regulations means the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 together with the circulars issued thereunder, including any statutory modification(s) or re-enactment(s) thereof for the time being in force.

  • CFTC Regulations means the rules and regulations promulgated by the CFTC, as amended.

  • ISA Regulations means The Individual Savings Account Regulations 1998, as amended or replaced from time to time.

  • CDM Regulations means the Construction (Design and Management) Regulations 2015;

  • UCITS Regulations means the European Communities Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 (S.I. No. 352 of 2011) (as amended consolidated or substituted from time to time) and any regulations or notices issued by the Central Bank pursuant thereto for the time being in force.

  • FCC Regulations means the regulations duly and lawfully promulgated by the FCC, as in effect from time to time.

  • TUPE Regulations means the Transfer of Undertakings (Protection of Employment) Regulations 2006, as amended.

  • WHFIT Regulations Treasury Regulations section 1.671-5, as amended.

  • HIPAA Regulations means the regulations promulgated under HIPAA by the United States Department of Health and Human Services, including, but not limited to, 45 C.F.R. Part 160 and 45 C.F.R. Part 164.

  • Radio Regulations means the Radio Regulations annexed to, or regarded as being annexed to, the most recent International Telecommunication Convention which may be in force at any time.

  • OFAC Regulations means the regulations promulgated by OFAC, as amended from time to time.

  • EU Regulation means a regulation within the meaning of Article 288 of the Treaty on the Functioning of the European Union;

  • TRADES Regulations means the regulations of the United States Department of the Treasury, published at 31 C.F.R. Part 357, as amended from time to time. Unless otherwise defined herein, all terms defined in the TRADES Regulations are used herein as therein defined.

  • Privacy Regulations means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011, 2015 and 2016 and as may be further amended from time to time;

  • FHA Regulations Regulations promulgated by HUD under the National Housing Act, codified in 24 Code of Federal Regulations, and other HUD issuances relating to FHA Loans, including the related handbooks, circulars, notices and mortgagee letters.