Rev. Rul. 71-586
Rev. Rul. 71-586; 1971-2 C.B. 380
- Cross-Reference
26 CFR 147.10-1: Election to treat certain debt obligations as
subject to tax.
- LanguageEnglish
- Tax Analysts Electronic Citationnot available
The purpose of this Revenue Ruling is to publish the list of obligations that domestic obligors have as of October 31, 1971, elected to have treated as debt obligations of a foreign obligor in accordance with section 4912(c) of the Internal Revenue Code of 1954.
The effect of such election is that the acquisition by United States persons of the debt obligations with respect to which the election was made by the domestic obligor are subject to interest equalization tax at the rate applicable to acquisitions of stock under section 4911(b) of the Code. The exemptions and exclusions from interest equalization tax such as the exemption for prior American ownership and compliance under section 4918 of the Code are not applicable on the acquisition by a United States person of such debt obligations. The described debt obligations are subject to the interest equalization tax even if the period remaining to maturity is less than one year. However, refunds or credits provided by section 4919 of the Code may be applicable on acquisitions of such debt obligations.
The names of obligors and the description of the obligations with respect to which elections have been made as of October 31, 1971 follow:
Name and Address of Issuer Description of Obligation
Amax International Capital Corp., 83/4% Guaranteed Sinking Fund
New York, N.Y. Debentures (Series A) due April
1, 1986; effective date April
22, 1971.
Amax International Capital Corp. 83/4% Guaranteed Sinking Fund
New York, N.Y. Debentures due April 1, 1986;
effective date April 23, 1971.
Continental Oil International Fin- 51/4% Promissory Notes not
ance Corp., New York, N.Y. convertible or exchangeable for
stock, minimum amount 100,000
Swiss Francs, Series Number 1
to 500, effective date May 12,
1971.
Amax International Capital Corp., 8% Guaranteed Notes due April 1,
New York, N.Y. 1976; effective date June 16,
1971.
IBM World Trade Corp., New York 63/4% Swiss Franc Notes of 1971
N.Y -76; effective date June 23,
1971.
Olin International Corp., Stam- 91/2% Unsecured Promissory Notes
ford, Conn. due January 6, 1975; effective
date June 24, 1971.
Atlantic Residex Corp., Marmora, 10% Series A Notes due June 30,
N.J. 1978; effective July 9, 1971.
The Singer Co., New York, N.Y. 43/8% Swiss Franc Notes dated
July 15, 1971 maturing October
14, 1971, numerals 1000;
effective date July 15, 1971.
Macfor International Finance Co., 71/4% Swiss Franc Notes Date of
San Francisco, Calif. Issue July 30, 1971, due July
30, 1976; effective date July
30, 1971.
Honeywell Overseas Finance Co., Promissory Notes payable to J.
Minneapolis, Minn. Henry Schroder Wagg & Co. Ltd.
maturing either 3 months or 6
months following issue date;
effective date August 23, 1971.
Illinois Tool Works Inc., Chicago, Swiss Francs Eight Million 71/2%
Ill. Notes, date of issue September
1, 1971, due September 1, 1976;
effective date August 27, 1971.
Union Oil Overseas Finance Corp., 4 year 7% Swiss Franc Notes of
Wilmington, Del. Swiss Francs 100,000,000 due
August 27, 1975, date of issue,
August 27, 1971, effective
date August 26, 1971.
Wells Fargo International Invest- WFIIC's 5 year 71/4% Swiss Franc
ment Corp., San Francisco, Calif. Notes of Swiss Francs
80,000,000--nominal amount due
September 15, 1976; effective
date September 9, 1971.
GTE International Inc., New York, 61/4% Loan of 1971 of one hundred
N.Y. million Swiss Francs; effective
date October 4, 1971.
IBM World Trade Corp., New York, 61/4% Swiss Franc Bonds of 1971
N.Y. -86: effective date October 4,
1971.
The Goodyear Tire & Rubber Co., International Issue--1971 short
Akron, Ohio. -term promissory notes non-
interest bearing; effective date
October 7, 1971.
Bristol-Myers Co., New York, N.Y. Euro C/P--Series A Promissory
Notes, noninterest bearing;
effective date October 12, 1971.
The Singer Co., New York, N.Y. The Singer Company Swiss Franc
Notes, Series A, interest
bearing short-term promissory
notes, serial numbers commence
with letter "A"; effective date
October 13, 1971.
Borg-Warner Corp., Chicago, Ill Europaper Series A Promissory
Notes, noninterest bearing;
effective date October 12, 1971.
Woolworth International Credit Guaranteed non-interest bearing
Corp., New York, N.Y. short-term promissory notes,
dated September 30, 1971 and due
December 15, 1971; effective
date September 27, 1971.
Goodyear International Finance Deutsche Mark Bearer Notes, 61/4%
Corp., Akron, Ohio. Guaranteed Notes Due April 1,
1976. Notes not registered and
nonconvertible effective date
October 18, 1971.
Goodyear International Finance Swiss Franc Bearer Bonds; 7%
Corp., Akron, Ohio. Guaranteed Bonds due July 15,
1985. Bonds not registered and
nonconvertible, effective date
October 18, 1971.
Chrysler Financial Corp., South- One $4,980,000 promissory note to
field, Mich. Hambros Bank, Ltd.,
nonconvertible, payable in five
equal semi-annual installments
commencing on October 25, 1974;
effective date October 22, 1971.
Massey-Ferguson Credit Corp., Des 73/4% Subordinated Swiss Franc
Moines, Iowa. Loan in aggregate principal
amount of 20,000,000 Swiss
Francs. Non-convertible not
exchangeable, or subject to
sinking fund requirements;
effective date October 28,
1971.
- Cross-Reference
26 CFR 147.10-1: Election to treat certain debt obligations as
subject to tax.
- LanguageEnglish
- Tax Analysts Electronic Citationnot available
