March 19, 2015 /PRNewswire/ -- Union Pacific Railroad Company announced today that it has determined the contingent interest
and sinking fund payments due in respect of Available Net Income for 2014 under the terms of certain bonds and debentures originally issued by the Missouri Pacific Railroad Company (MPRR).
Welcoming it as a "good transaction" for stakeholders, MOG added : "Rockhopper's offer represents an opportunity for MOG shareholders to receive shares in Rockhopper, while still retaining a contingent interest
in the high risk exploration well offshore Malta that will spud in the next few days".
29) While it generally would not be possible to pay contingent interest
tax-free under the so-called "portfolio interest" rules, (30) a limited statutory exception does exist that would allow non-U.
For instruments with variable or contingent interest
payments, taxpayers must apply special OID rules for determining the adjusted yield.
Lenders who will receive contingent interest
need to reach agreements with their borrowers regarding repayment schedules.
equity kickers, contingent interest
, significant deferral
will be payable for the period October 1, 2012 until March 31, 2013.
776696AA4) (the "Notes") will accrue contingent interest
for the semi-annual period beginning July 16, 2014.
Taxpayers may attempt to use debt instruments with contingent interest
features to avoid IRC section 897.
There would be no sharing arrangement or contingent interest
between Sinclair and the Birmingham Buyer, except possibly a transitional shared facilities agreement as discussed below.
The taxpayer argued that the estate's contingent interest
should not be considered in the calculation, resulting in a $6,000 gift to each beneficiary.
2002-31, the IRS concluded that a convertible debt instrument issued with contingent interest
that is neither "remote nor incidental" is subject to the Regs.