IRS Announces OID Inflation-Adjusted Dollar Amounts For 2002.
Rev. Rul. 2001-65; 2001-2 C.B. 1
- Institutional AuthorsInternal Revenue Service
- Cross-ReferencePart I
- Code Sections
- Subject Area/Tax Topics
- Index TermsOID, small issues
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2001-30969 (4 original pages)
- Tax Analysts Electronic Citation2001 TNT 242-12
Suplemented and Superseded by Rev. Rul. 2002-79
Rev. Rul. 2001-65
[1] This revenue ruling provides the dollar amounts, increased by the 2002 inflation adjustment, for §1274A of the Internal Revenue Code.
BACKGROUND
[2] In general, §§483 and 1274 determine the principal amount of a debt instrument given in consideration for the sale or exchange of nonpublicly traded property. In addition, any interest on a debt instrument subject to §1274 is taken into account under the original issue discount provisions of the Code. Section 1274A, however, modifies the rules under §§483 and 1274 for certain types of debt instruments.
[3] In the case of a "qualified debt instrument," the discount rate used for purposes of §§483 and 1274 may not exceed 9 percent, compounded semiannually. Section 1274A(b) defines a qualified debt instrument as any debt instrument given in consideration for the sale or exchange of property (other than new §38 property within the meaning of §48(b), as in effect on the day before the date of enactment of the Revenue Reconciliation Act of 1990) if the stated principal amount of the instrument does not exceed the amount specified in §1274A(b). For debt instruments arising out of sales or exchanges before January 1, 1990, this amount is $2,800,000.
[4] In the case of a "cash method debt instrument," as defined in §1274A(c), the borrower and lender may elect to use the cash receipts and disbursements method of accounting. In particular, for any cash method debt instrument, §1274 does not apply, and interest on the instrument is accounted for by both the borrower and the lender under the cash method of accounting. A cash method debt instrument is a qualified debt instrument that meets the following additional requirements: (A) In the case of instruments arising out of sales or exchanges before January 1, 1990, the stated principal amount does not exceed $2,000,000; (B) the lender does not use an accrual method of accounting and is not a dealer with respect to the property sold or exchanged; (C) §1274 would have applied to the debt instrument but for an election under §1274A(c); and (D) an election under §1274A(c) is jointly made with respect to the debt instrument by the borrower and lender. Section 1.1274A-1(c)(1) of the Income Tax Regulations provides rules concerning the time for, and manner of, making this election.
[5] Section 1274A(d)(2) provides that, for any debt instrument arising out of a sale or exchange during any calendar year after 1989, the dollar amounts stated in §1274A(b) and §1274A(c)(2)(A) are increased by the inflation adjustment for the calendar year. Any increase due to the inflation adjustment is rounded to the nearest multiple of $100 (or, if the increase is a multiple of $50 and not of $100, the increase is increased to the nearest multiple of $100). The inflation adjustment for any calendar year is the percentage (if any) by which the CPI for the preceding calendar year exceeds the CPI for calendar year 1988. Section 1274A(d)(2)(B) defines the CPI for any calendar year as the average of the Consumer Price Index as of the close of the 12-month period ending on September 30 of that calendar year.
INFLATION-ADJUSTED AMOUNTS
[6] For debt instruments arising out of sales or exchanges after December 31, 1989, the inflation-adjusted amounts under §1274A are shown in Table 1.
Rev. Rul. 2001-65
Table 1
Inflation-Adjusted Amounts Under §1274A
Calendar Year 1274A(b) Amount 1274A(c)(2)(A) Amount
of Sale (qualified debt (cash method debt
or Exchange instrument) instrument)
1990 $2,933,200 $2,095,100
1991 $3,079,600 $2,199,700
1992 $3,234,900 $2,310,600
1993 $3,332,400 $2,380,300
1994 $3,433,500 $2,452,500
1995 $3,523,600 $2,516,900
1996 $3,622,500 $2,587,500
1997 $3,723,800 $2,659,900
1998 $3,823,100 $2,730,800
1999 $3,885,500 $2,775,400
2000 $3,960,100 $2,828,700
2001 $4,085,900 $2,918,500
2002 $4,217,500 $3,012,500
Note: These inflation adjustments were computed using the
All-Urban, Consumer Price Index, 1982-1984 base, published
by the Bureau of Labor Statistics.
EFFECT ON OTHER DOCUMENTS
[7] Rev. Rul. 2000-55, 2000-52 I.R.B. 595, is supplemented and superseded.
DRAFTING INFORMATION
[8] The principal author of this revenue ruling is Courtney Shepardson the Office of the Assistant Chief Counsel (Financial Institutions and Products). For further information regarding this revenue ruling contact Ms. Shepardson on (202) 622-3930 (not a toll- free call).
- Institutional AuthorsInternal Revenue Service
- Cross-ReferencePart I
- Code Sections
- Subject Area/Tax Topics
- Index TermsOID, small issues
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2001-30969 (4 original pages)
- Tax Analysts Electronic Citation2001 TNT 242-12