Examples of Operating note in a sentence
The Crescent Operating Note possesses a number of attributes weighing in favor of debt treatment.
Further, it is our opinion that amounts designated as interest by the Crescent Operating Note will be treated as interest for purposes of the 95 percent gross income test of section 856(c).
For instance, the Crescent Operating Note is clearly denominated as debt, has a fixed maturity date of five years, provides for the return of interest on the principal amount at a rate of 12 percent per annum, and is secured by the Assets.
Based on the foregoing, it is our opinion that the Crescent Operating Note constitutes debt for federal income tax purposes.
Characterization of the Crescent Operating Note Debt instruments, especially instruments that are held by persons related to the debtor, may under certain circumstances be characterized for income tax purposes as equity, rather than as debt.