For the next subscription period, that is, November 27 - 29, the issue price
shall be Rs 2,961 per gram with settlement on December 4, as published by the RBI.
For a contingent debt instrument that is not publicly traded and is issued in exchange for nontraded property, the issue price
is determined based only on the debt's fixed components.
Shares in Punch, Britain's second-largest pubs group, rose as high as 245p in limited dealing and ahead of full trading on Monday, well up on the 230p issue price
that institutional investors paid and closed at 241 1 /2p.
The fully diluted figure assumes conversion of $20 million in original issue price
zero coupon convertible notes still outstanding to Elan (convertible at $14 per share).
Three special rules are added: (a) the value of the equity shall include the tax basis of the assets (and not, as normal in a debt-equity analysis, the fair market value of the assets);17 (b) the issue price
of debt, plus accrued OID, shall control; and (c) all members of an affiliated group "shall be treated as 1 taxpayer.
The unmodified note's adjusted issue price
is $75,000 and the modified note's issue price
is $50,000; see Sec.
1273(a)(1) provides that OID is the excess of the stated redemption price at maturity over the issue price
At conversion, the holder does not recognize any income, and the issuer cannot deduct as interest the excess of the stock's FMV over the debt's adjusted issue price
the excess of the new debt's issue price
over the original debt's adjusted issue price
) is attributable, in part, to the fact that the taxpayer previously claimed a deduction for partial worthlessness (thus reducing its basis in the debt), and the modification does not alter the fact that a portion of the debt remains uncollectible.