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ARTICLE · 27 SEPTEMBER 2012

IRS Finalizes Regulations For Determining Publicly Traded Property

Grant Thornton LLP
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The IRS has issued final regulations (T.D. 9599) under Section 1273 related to whether property is publicly traded under Treas. Reg. Sec. 1.1273-2(f).

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Grant Thornton'S Washington National Tax Office
Grant Thornton'S Washington National Tax Office
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The IRS has issued final regulations (T.D. 9599) under Section 1273 related to whether property is publicly traded under Treas. Reg. Sec. 1.1273-2(f).

The issue price of a debt instrument has relevance for various sections of the code (e.g., sections 108, 1001, and 1271 through 1275), and can be effected by whether the debt instrument is considered publicly traded. Section 1273(b) provides general rules to determine the issue price of a debt instrument, and if a debt instrument is issued for property and either such debt instrument or such property is "traded on an established market" as defined Treas. Reg. Sec. 1.1273-2(f) (i.e., publicly traded), the issue price of the debt instrument is equal to the fair market value of the publicly traded property.

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