Publication 1212 |
2000 Tax Year |
Information for Owners of OID Debt Instruments
This section is for persons who prepare their own tax returns. It
discusses the income tax rules for computing and reporting OID on
long-term debt instruments. It also includes a similar discussion for
stripped bonds and coupons, such as zero coupon instruments available
through the Department of the Treasury's STRIPS program and
government-sponsored enterprises such as the Resolution Funding
Corporation. However, the information provided does not cover every
situation. More information can be found in the regulations under
sections 1271 through 1275 of the Internal Revenue Code.
Reporting OID.
Generally, you report OID as it accrues each year, whether or not
you receive any payments from the bond issuer.
Exceptions.
The rules for reporting OID on long-term instruments do not apply
to the following debt instruments.
- U.S. savings bonds.
- Tax-exempt obligations. (However, see Tax-Exempt Bonds
and Coupons, later.)
- Obligations issued by individuals before March 2,
1984.
- Loans of $10,000 or less between individuals who are not in
the business of lending money. (The dollar limit includes outstanding
prior loans by the lender to the borrower.) This exception does not
apply if a principal purpose of the loan is to avoid any federal
tax.
See chapter 1 of Publication 550
for information about the rules
for these and other types of discounted instruments such as short-term
and market discount obligations. Publication 550
also discusses rules
for holders of REMIC interests and CDOs.
De minimis rule.
You can treat OID as zero if the total OID on a debt instrument is
less than one-fourth of 1% (.0025) of the stated redemption price at
maturity multiplied by the number of full years from the date of
original issue to maturity. Long-term instruments with de minimis OID
are not listed in this publication.
Example 2.
You bought at issuance a 10-year bond with a stated redemption
price at maturity of $1,000, issued at $980 with OID of $20.
One-fourth of 1% of $1,000 (the stated redemption price) times 10 (the
number of full years from the date of original issue to maturity)
equals $25. Under the de minimis rule, you can treat the OID as zero
because the $20 discount is less than $25.
Example 3.
Assume the same facts as Example 2, except the bond was
issued at $950. You must report part of the $50 OID each year because
it is more than $25.
Election to report all interest as OID.
Generally, you can elect to treat all interest on a debt instrument
acquired after April 3, 1994, as OID and include it in gross income by
using the constant yield method. See Figuring OID using the
constant yield method under Debt Instruments Issued After
1984, later, for more information.
For purposes of this election, interest includes stated interest,
acquisition discount, OID, de minimis OID, market discount, de minimis
market discount, and unstated interest, as adjusted by any amortizable
bond premium or acquisition premium. See section 1.1272-3 of the
regulations for more information.
Purchase after date of original issue.
A debt instrument you purchased after the date of original issue
may have premium, acquisition premium, or market discount. (These
terms are defined later.) If so, the OID reported to you on Form
1099-OID may have to be adjusted. For more information, see
Showing an OID adjustment under How To Report OID,
later.
Adjustment for premium.
If your debt instrument (other than a contingent payment debt
instrument or an inflation-indexed debt instrument) has premium, do
not report any OID as ordinary income. Your adjustment is the total
OID shown on your Form 1099-OID.
Adjustment for acquisition premium.
If your debt instrument has acquisition premium, reduce the OID you
report. Your adjustment is the difference between the OID shown on
your Form 1099-OID and the reduced OID amount figured using the
rules explained later under Figuring OID on Long-Term Debt
Instruments.
Adjustment for market discount.
If your debt instrument has market discount that you choose to
include in income currently, increase the OID you report. Your
adjustment is the accrued market discount for the year.
See Market Discount Bonds in chapter 1 of Publication 550
for information on how to figure accrued market discount and
include it in your income currently, and for other information about
market discount bonds. If you elect to use the constant yield method
to figure accrued market discount, also see Figuring OID on
Long-Term Debt Instruments, later. The constant yield method of
figuring accrued OID, explained in those discussions under
Figuring OID using the constant yield method, is also used
to figure accrued market discount.
Sale, exchange, or redemption.
Generally, you treat your gain or loss from the sale, exchange, or
redemption of a discounted bond or other debt instrument as a capital
gain or loss if you held the bond as a capital asset. If you sold the
bond through a broker, you should receive Form 1099-B or an
equivalent statement from the broker. Use the Form 1099-B or
other statement and your brokerage statements to complete Schedule D
(Form 1040).
Your gain or loss is the difference between the amount you realized
on the sale, exchange, or redemption and your basis in the debt
instrument. Your basis, generally, is your cost increased by the OID
you have included in income each year you held it. To determine your
gain or loss on a tax-exempt bond, figure your basis in the bond by
adding to your cost the OID you would have included in income if the
bond had been taxable.
See chapter 4 of Publication 550
for more information about the tax
treatment of the sale or redemption of discounted debt instruments.
Example 4.
On November 1, 1997, Larry, a calendar year taxpayer, bought a
corporate bond at original issue for $86,235.17. The 15-year bond
matures on October 31, 2012, at a stated redemption price of $100,000.
The bond provides for semiannual payments of interest at 10%. Assume
the bond is a capital asset in Larry's hands. The bond has $13,764.83
of OID ($100,000 stated redemption price at maturity less $86,235.17
issue price).
On November 1, 2000, Larry sold the bond for $90,000. Including the
OID he will report for the period he held the bond in 2000, Larry has
included $1,214.48 of OID in income and has increased his basis by
that amount to $87,449.65. Larry has realized a gain of $2,550.35. All
of Larry's gain is capital gain.
Definitions
The following terms are used throughout this publication. For your
convenience, "original issue discount" is defined first. The
other terms are listed alphabetically.
Original issue discount (OID).
OID is a form of interest. It is the difference between the stated
redemption price and the issue price. A debt instrument generally has
OID when it is issued for a price less than its stated redemption
price at maturity. All debt instruments that pay no interest before
maturity (for example, zero coupon bonds) are presumed to be issued at
a discount.
Accrual period.
An accrual period is an interval of time used to measure OID. The
length of an accrual period can be six months, a year, or some other
period, depending on when the debt instrument was issued.
Acquisition premium.
Acquisition premium is the difference between the adjusted basis
and the adjusted issue price. A debt instrument is purchased at an
acquisition premium if both the following apply.
- It is not purchased at a premium.
- Its adjusted basis immediately after purchase, including
purchase at original issue, is greater than its adjusted issue
price.
Adjusted issue price.
The adjusted issue price of a debt instrument at the beginning of
an accrual period is used to figure the OID allocable to that period.
In general, the adjusted issue price at the beginning of the
instrument's first accrual period is its issue price. The adjusted
issue price at the beginning of any subsequent accrual period is the
sum of the issue price and all the OID includible in income before
that accrual period minus any payment previously made on the
instrument, other than a payment of qualified stated interest.
Debt instrument.
The term "debt instrument" means a bond, debenture, note,
certificate, or other evidence of indebtedness. It generally does not
include an annuity contract.
Issue price.
For instruments listed in Section I-A and
Section I-B, the issue price is the initial offering
price to the public (excluding bond houses and brokers) at which a
substantial amount of these instruments was sold.
Market discount.
Market discount arises when a debt instrument purchased in the
secondary market has decreased in value since its issue date,
generally because of an increase in interest rates. An OID bond has
market discount if your adjusted basis in the bond immediately after
you acquired it (usually its purchase price) was less than the bond's
issue price plus the total OID that accrued before you acquired it.
The market discount is the difference between the issue price plus
accrued OID and your adjusted basis.
Premium.
A debt instrument is purchased at a premium if its adjusted basis
immediately after purchase is greater than the total of all amounts
payable on the instrument after the purchase date, other than
qualified stated interest. The premium is the difference between the
adjusted basis and the payable amounts.
Qualified stated interest.
In general, qualified stated interest is stated interest that is
unconditionally payable in cash or property (other than debt
instruments of the issuer) at least annually over the term of the
instrument at a single fixed rate.
Stated redemption price at maturity.
An instrument's stated redemption price at maturity is the sum of
all amounts (principal and interest) payable on the instrument other
than qualified stated interest.
Yield to maturity (YTM).
In general, the YTM is the discount rate that, when used in
figuring the present value of all principal and interest payments,
produces an amount equal to the issue price of the bond. The YTM is
generally shown on the face of the bond or in the literature you
receive from your broker. If you do not have this information, consult
your broker, tax advisor, or the issuer.
Form 1099-OID
The issuer of the debt instrument (or your broker, if you purchased
or held the instrument through a broker) should give you a copy of
Form 1099-OID, or a similar statement, if the accrued OID for
the calendar year is $10 or more and the term of the instrument is
more than one year. Form 1099-OID shows all OID income in box 1
except OID on a U.S. Treasury obligation, which is shown in box 6. It
also shows, in box 2, any qualified stated interest you must include
in income. (However, any qualified stated interest on Treasury
inflation-indexed securities that is not OID can be reported in box 3
of Form 1099-INT.) A copy of Form 1099-OID will be sent to
the IRS. Do not attach your copy to your tax return. Keep it for your
records.
If you are required to file a tax return and you receive Form
1099-OID showing taxable amounts, you must report these amounts
on your return. A 20% accuracy-related penalty may be charged for
underpayment of tax due to either of the following reasons.
- Negligence or disregard of rules and regulations.
- Substantial understatement of tax.
Form 1099-OID not received.
If you held an OID instrument for 2000 but did not receive a Form
1099-OID, refer to the later discussions under Figuring OID
on Long-Term Debt Instruments for information on the OID you
must report.
Refiguring OID.
You must refigure the OID shown in box 1 or box 6 of Form
1099-OID to determine the proper amount to include in income if
one of the following applies.
- You bought the debt instrument at a premium or at an
acquisition premium.
- The debt instrument is a stripped bond or coupon (including
zero coupon instruments backed by U.S. Treasury securities).
- The debt instrument is a contingent payment or
inflation-indexed debt instrument.
See the discussions under Figuring OID on Long-Term Debt
Instruments or Figuring OID on Stripped Bonds and Coupons,
later, for the specific computations.
Refiguring interest.
If you disposed of a debt instrument or acquired it from another
holder between interest dates, see the discussion under Bonds
Sold Between Interest Dates in chapter 1 of Publication 550
for
information about refiguring the interest shown in box 2 of Form
1099-OID.
Nominee.
If you are the holder of an OID instrument and you receive a Form
1099-OID that shows your taxpayer identification number and
includes amounts belonging to another person, you are considered a
"nominee." You must file another Form 1099-OID for each
actual owner, showing the OID for the owner. Show the owner of the
instrument as the "recipient" and you as the "payer."
Complete Form 1099-OID and Form 1096 and file the forms with
the Internal Revenue Service Center for your area. You must also give
a copy of the Form 1099-OID to the actual owner. However, you
are not required to file a nominee return to show amounts belonging to
your spouse. See the Form 1099 instructions for more information.
When preparing your tax return, follow the instructions under
Showing an OID adjustment in the next discussion.
How To Report OID
Generally, you report your taxable interest and OID income on line
2, Form 1040EZ; line 8a, Form 1040A; or line 8a, Form 1040.
Form 1040 or Form 1040A required.
Unless you are a nominee for the actual owner of the debt
instrument, you must use Form 1040 if you are reporting more or less
OID than the amount shown on Form 1099-OID. For example, if you
paid a premium or an acquisition premium when you purchased the debt
instrument, you must use Form 1040 because you will report less OID
than shown on Form 1099-OID. Also, you must use Form 1040 if you
were charged an early withdrawal penalty.
You must use Form 1040 or Form 1040A (you cannot use Form 1040EZ)
under either of the following conditions.
- You received a Form 1099-OID as a nominee for the
actual owner.
- Your total interest and OID income for the year was more
than $400.
Where to report.
List each payer's name (if a brokerage firm gave you a Form 1099,
list the brokerage firm as the payer) and the amount received from
each payer on line 1 of Schedule 1 (Form 1040A) or line 1 of Schedule
B (Form 1040). Include all OID and periodic interest shown in boxes 1,
2, and 6 of any Form 1099-OID you received for the tax year.
Also include any other OID and interest income for which you did not
receive a Form 1099.
Showing an OID adjustment.
If you use Form 1040 to report more or less OID than shown on Form
1099-OID, list the full OID on line 1, Part I of Schedule B and
follow the instructions under (1) or (2), next.
If you use Form 1040A to report the OID shown on a Form
1099-OID you received as a nominee for the actual owner, list
the full OID on line 1, Part I of Schedule 1 and follow the
instructions under (1).
- If the OID, as adjusted, is less than the amount shown on
Form 1099-OID, show the adjustment as follows.
- Under your last entry on line 1, subtotal all interest and
OID income listed on line 1.
- Below the subtotal write "Nominee Distribution" or
"OID Adjustment" and show the OID you are not required to
report.
- Subtract that OID from the subtotal and enter the result on
line 20.
- If the OID, as adjusted, is more than the amount shown on
Form 1099-OID, show the adjustment as follows.
- Under your last entry on line 1, subtotal all interest and
OID income listed on line 1.
- Below the subtotal write "OID Adjustment," and show the
additional OID.
- Add that OID to the subtotal.
Figuring OID
on Long-Term Debt Instruments
How you figure the OID on a long-term debt instrument depends on
the date it was issued. It also may depend on the type of the
instrument. There are different rules for each of the following debt
instruments.
- Corporate debt instruments issued after 1954 and before May
28, 1969, and government instruments issued after 1954 and before July
2, 1982.
- Corporate debt instruments issued after May 27, 1969, and
before July 2, 1982.
- Debt instruments issued after July 1, 1982, and before
1985.
- Debt instruments issued after 1984 (other than debt
instruments described in (5) and (6)).
- Contingent payment debt instruments issued after August 12,
1996.
- Inflation-indexed debt instruments (including Treasury
inflation-indexed securities) issued after January 5, 1997.
Zero coupon instrument.
The rules for figuring OID on zero coupon instruments backed by
U.S. Treasury securities are discussed later under Figuring OID
on Stripped Bonds and Coupons, later.
Corporate Debt Instruments Issued After 1954 and
Before May 28, 1969,
and Government Instruments Issued After 1954 and
Before July 2, 1982
For these instruments, you do not include OID in income until the
year the instrument is sold, exchanged, or redeemed. If a gain results
and the instrument is a capital asset, the OID is taxed as ordinary
income. The balance of the gain is capital gain. If there is a loss on
the sale of the instrument, the entire loss is a capital loss and no
OID is reported.
The gain taxed as ordinary income when the instrument is sold,
exchanged, or redeemed generally equals the following amount:
Corporate Debt Instruments Issued After May 27, 1969, and
Before July 2, 1982
If you hold these debt instruments as capital assets, you must
include part of the discount in income each year you own the
instruments. For information about showing the correct OID on your tax
return, see the discussion under How To Report OID,
earlier. Your basis in the instrument is increased by the OID
you include in income.
Form 1099-OID.
You should receive a Form 1099-OID showing OID for the part
of the year you held the bond. However, if you paid an acquisition
premium, you may need to refigure the OID to report on your tax
return. See Acquisition premium, later.
Form 1099-OID not received.
If you held an OID instrument in 2000 but did not receive a Form
1099-OID, refer to Section I-A later in this
publication. The OID listed is for each $1,000 of redemption price.
You must adjust the listed amount if your debt instrument has a
different principal amount. For example, if you have an instrument
with a $500 principal amount, use one-half of the listed amount to
figure your OID.
If you held the instrument the entire year, use the OID shown in
Section I-A for calendar year 2000. (If your
instrument is not listed in Section I-A, consult the
issuer for information about the issue price, yield to maturity, and
the OID that accrued for 2000.) If you did not hold the instrument the
entire year, figure your OID using the following method.
- Divide the OID shown for 2000 by 12.
- Multiply the result in (1) by the number of complete and
partial months (for example, 6 1/2 months) you held the
debt instrument in 2000. This is the OID to include in income unless
you paid an acquisition premium. The reduction for acquisition premium
is discussed next.
Acquisition premium.
If you bought the debt instrument at an acquisition premium, figure
the OID to include in income as follows.
- Divide the total OID on the instrument by the number of
complete months, and any part of a month, from the date of original
issue to the maturity date. This is the ratable monthly
portion.
- Subtract from your cost the issue price and the accumulated
OID from the date of issue to the date of purchase. (If the result is
zero or less, stop here. You did not pay an acquisition
premium.)
- Divide the amount figured in (2) by the number of complete
months, and any part of a month, from the date of your purchase to the
maturity date.
- Subtract the amount figured in (3) from the amount figured
in (1). This is the OID to include in income for each month you hold
the instrument during the year.
Example 5.
On June 1, 1982, Acme Corporation issued 20-year bonds at 90% of
the principal amount. On February 1, 2000, you bought Acme bonds with
a $10,000 principal amount on the open market for $9,900. The amount
you must include in income is figured as follows:
1) |
Ratable monthly portion ($1,000
total OID x 240 months) |
$4.17 |
2) |
Your cost |
$9,900.00 |
| Minus: Issue price |
9,000.00 |
| | $ 900.00 |
| Minus: Accumulated OID ($4.17 x 212
months) |
884.04 |
| Acquisition premium |
$ 15.96 |
3) |
Acquisition premium divided
by number of complete and
partial months from date of
purchase to maturity date
($15.96 x 28 months) |
0.57 |
4) |
Line 1 minus line 3 |
$3.60 |
You must include $39.60 ($3.60 x 11 months) in income for
2000 because the acquisition premium reduces the ratable monthly
portion of OID.
Example 6.
Assume the same facts as Example 5, except that you
bought the bonds for $9,844.04. In this case, your cost equals the
original issue price plus accumulated OID. Therefore, you did not pay
an acquisition premium. For 2000, include $45.87 ($4.17 x 11
months) of OID in income.
Example 7.
Assume the same facts as Example 5, except that you
bought the bonds for $9,400. In this case, you must include $45.87 of
OID in your 2000 income. You did not pay an acquisition premium
because you bought the bonds for less than the sum of the original
issue price plus accumulated OID. The bonds have market discount,
which must be reported under the rules explained in chapter 1 of
Publication 550.
Transfers during the month.
If you buy or sell a debt instrument on any day other than the same
day of the month as the date of original issue, the ratable monthly
portion of OID for the month of sale is divided between the seller and
the buyer according to the number of days each held the instrument.
Your holding period for this purpose begins the day you
obtain the instrument and ends the day before you dispose of it.
Example 8.
Assume the same facts as Example 5, except that you
bought the bonds on September 14, 1999, for $9,865.00 ($9,000 issue
price plus $865 accumulated OID) and sold them on March 14, 2000. You
figure the OID to include in your 1999 income as follows:
Amount for September ($4.17 x 17 days
x 30 days) |
$ 2.36 |
Amount for complete months October through
December ($4.17 x 3 months) |
12.51 |
Total to include in 1999 income |
$14.87 |
You figure the OID to include in your 2000 income as follows:
Amount for complete months January through
February ($4.17 x 2 months) |
$8.34 |
Amount for March ($4.17 x 13 days
x 31 days) |
1.75 |
Total to include in 2000 income |
$10.09 |
You increase your basis in the bonds by the OID you include in
income. Your basis in the bonds when you sold them is $9,889.96
($9,865 cost + $14.87 OID for 1999 and $10.09 OID for 2000).
Debt Instruments Issued
After July 1, 1982, and
Before 1985
If you hold these debt instruments as capital assets, you must
include part of the OID in income each year you own the instruments
and increase your basis by the amount included. For information about
showing the correct OID on your tax return, see How To Report
OID, earlier.
Form 1099.
You should receive a Form 1099-OID showing OID for the part
of the year you held the bond. However, if you paid an acquisition
premium, you may need to refigure the OID to report on your tax
return. See Figuring OID using the constant yield method
and the discussions on acquisition premium that follow, later.
Form 1099-OID not received.
If you held an OID instrument during the year but did not receive a
Form 1099-OID, refer to Section I-A later in
this publication. The OID listed is for each $1,000 of redemption
price. You must adjust the listed amount if your debt instrument has a
different principal amount. For example, if you have an instrument
with a $500 principal amount, use one-half of the listed amount to
figure your OID.
If you held the debt instrument the entire year, use the OID shown
in Section I-A for calendar year 2000. (If your
instrument is not listed in Section I-A, consult the
issuer for information about the issue price, yield to maturity, and
the OID that accrued for 2000.) If you did not hold the debt
instrument the entire year, figure your OID using either of the
following methods.
Method 1.
- Divide the total OID for 2000 by 366.
- Multiply the result in (1) by the number of days you held
the debt instrument in 2000.
This computation is an approximation and may result in a slightly
higher OID than Method 2.
Method 2.
- Look up the daily OID for the first 2000 accrual period you
held the instrument. (See Accrual period under
Figuring OID using the constant yield method, next.)
- Multiply the daily OID by the number of days in 2000 you
held the instrument during that accrual period.
- If you held the instrument for part of both 2000 accrual
periods, repeat (1) and (2) for the second accrual period.
- Add the results of (2) and (3). This is the OID to include
in income for 2000, unless you paid an acquisition premium. (The
reduction for acquisition premium is discussed later.)
Figuring OID using the constant yield method.
This discussion shows how to figure OID on debt instruments issued
after July 1, 1982, and before 1985, using a constant yield method.
OID is allocated over the life of the instrument through adjustments
to the issue price for each accrual period.
Figure the OID allocable to any accrual period as follows.
- Multiply the adjusted issue price at the beginning of the
accrual period by the instrument's yield to maturity.
- Subtract from the result in (1) any qualified stated
interest allocable to the accrual period.
Accrual period.
An accrual period for any OID instrument issued after July 1, 1982,
and before 1985 is each one-year period beginning on the date of the
issue of the obligation and each anniversary thereafter, or the
shorter period to maturity for the last accrual period. Your tax year
will usually overlap more than one accrual period.
Daily OID.
The OID for any accrual period is allocated ratably to each day in
the accrual period. You must include in income the sum of the OID for
each day that you hold the instrument during the year. If your tax
year overlaps more than one accrual period, you must include the
proper daily OID amounts for each of the two accrual periods.
Figuring daily OID.
The daily OID for the initial accrual period is figured
using the following formula:
ip |
= |
issue price |
ytm |
= |
yield to maturity |
qsi |
= |
qualified stated interest |
p |
= |
number of days in accrual period |
The daily OID for subsequent accrual periods is figured
the same way except the adjusted issue price at the beginning of each
period is used in the formula instead of the issue price.
Example 9.
On January 1, 1984, you bought a 20-year, 13% bond for $90,000 at
original issue. The redemption price of the bond is $100,000. The
qualified stated interest is $13,000 (13% x $100,000), which is
unconditionally payable each year. The bond has a yield to maturity of
14.5587%. The daily OID for the first accrual period is figured as
follows:
You would have included in income $.28096 for each day you held the
bond during 1984. If you held the bond for all of 1984, you would have
included OID of $102.83 ($.28096 x 366).
The following table shows the adjusted issue price, daily OID, and
OID per accrual period through 2000.
Accrual
Period |
Year |
Adjusted
Issue
Price |
Daily OID |
OID per
Accrual
Period |
1 |
1984 |
$90,000.00 |
$.28096 |
$102.83 |
2 |
1985 |
90,102.83 |
.32274 |
117.80 |
3 |
1986 |
90,220.63 |
.36973 |
134.95 |
4 |
1987 |
90,355.58 |
.42356 |
154.60 |
5 |
1988 |
90,510.18 |
.48391 |
177.11 |
6 |
1989 |
90,687.29 |
.55586 |
202.89 |
7 |
1990 |
90,890.18 |
.63679 |
232.43 |
8 |
1991 |
91,122.61 |
.72951 |
266.27 |
9 |
1992 |
91,388.88 |
.83342 |
305.03 |
10 |
1993 |
91,693.91 |
.95737 |
349.44 |
11 |
1994 |
92,043.35 |
1.09677 |
400.32 |
12 |
1995 |
92,443.67 |
1.25644 |
458.60 |
13 |
1996 |
92,902.27 |
1.43541 |
525.36 |
14 |
1997 |
93,427.63 |
1.64890 |
601.85 |
15 |
1998 |
94,029.48 |
1.88896 |
689.47 |
16 |
1999 |
94,718.95 |
2.16397 |
789.85 |
17 |
2000 |
95,508.80 |
2.47224 |
904.84 |
The daily OID for the 18th accrual period is figured as follows:
If you hold the bond for all of 2001, you would include $1,036.57
in income ($2.83992 x 365).
Example 10.
Assume the same facts as Example 9, except that you
bought the bond at original issue on May 1, 1983. The daily OID for
the first accrual period (May 1, 1983 - April 30, 1984) was
$.28096, as figured in Example 9. If you held the bond
until the end of 1983, you would have included $68.84 in income for
1983 ($.28096 x 245 days). If you continued to hold the bond,
you would have included in income, for 1984 through 1999, the
following amounts of OID.
Year |
First Accrual
Period |
Second Accrual
Period |
Total |
1984 |
$.28096 x121 days |
$.32274 x245 days |
$113.07 |
1985 |
$.32274 x120 days |
$.36973 x245 days |
$129.31 |
1986 |
$.36973 x120 days |
$.42356 x245 days |
$148.14 |
1987 |
$.42356 x120 days |
$.48391 x245 days |
$169.39 |
1988 |
$.48391 x121 days |
$.55586 x245 days |
$194.74 |
1989 |
$.55586 x120 days |
$.63679 x245 days |
$222.71 |
1990 |
$.63679 x120 days |
$.72951 x245 days |
$255.14 |
1991 |
$.72951 x120 days |
$.83342 x245 days |
$291.73 |
1992 |
$.83342 x121 days |
$.95737 x245 days |
$335.40 |
1993 |
$.95737 x120 days |
$1.09677 x245 days |
$383.59 |
1994 |
$1.09677 x120 days |
$1.25644 x245 days |
$439.44 |
1995 |
$1.25644 x120 days |
$1.43541 x245 days |
$502.45 |
1996 |
$1.43541 x121 days |
$1.64890 x245 days |
$577.66 |
1997 |
$1.64890 x120 days |
$1.88896 x245 days |
$660.67 |
1998 |
$1.88896 x120 days |
$2.16397 x245 days |
$756.85 |
1999 |
$2.16397 x120 days |
$2.47224 x245 days |
$865.38 |
If you sold the bond on August 30, 2000, you would figure the
amount to include in your 2000 income as follows:
First accrual period: $2.47224 x 121 days
(Jan 1 - Apr 30) |
$299.14 |
Second accrual period: $2.83992 x 121
days (May 1 - Aug 29) |
343.63 |
Total to include in 2000 income |
$642.77 |
However, if you held the bond the entire year of 2000, the total
OID to report is $994.92 [$299.14 + $695.78 ($2.83992 x 245
days)].
Acquisition premium on debt instruments purchased before July
19, 1984.
If you bought the debt instrument at an acquisition premium before
July 19, 1984, you figure the reduction of OID includible in income by
reducing the daily OID by the daily acquisition premium. Figure the
daily acquisition premium by dividing the total acquisition premium by
the number of days in the period beginning on your purchase date and
ending on the day before the date of maturity.
Example 11.
Assume the same facts as Example 10, except that you
bought the bond for $92,000 on May 1, 1984, after its original issue
on May 1, 1983. In this case, you paid more for the bond than its
$90,102.83 adjusted issue price ($90,000 + $102.83). You paid
$1,897.17 ($92,000 - $90,102.83) acquisition premium. The daily
OID as reduced for the acquisition premium for the accrual period May
1, 1984, to April 30, 1985, is figured as follows:
1) |
Daily OID on date of purchase
(2nd accrual period) |
$.32274 |
2) |
Acquisition premium |
$1,897.17 |
3) |
Total days from purchase date to maturity date
[(365 x 19 years) + 4 days for leap years] |
6,939 |
4) |
Line 2 x line 3 |
$.27341 |
5) |
Daily OID reduced for the acquisition
premium. Line 1 - line 4 |
$.04933 |
The OID you would have included in income for 1984 is $12.09
($.04933 x 245 days).
Assuming you still owned the bond in 2000, you would have reduced
the total OID for each year (as determined in Example 10)
by the allocable portion of the acquisition premium for that
year. You would have included the following amounts of OID in income:
Year |
OID |
1985 |
$ 29.52 |
1986 |
$ 48.35 |
1987 |
$ 69.60 |
1988 |
$ 94.67 |
1989 |
$122.92 |
1990 |
$155.35 |
1991 |
$191.94 |
1992 |
$235.33 |
1993 |
$283.80 |
1994 |
$339.65 |
1995 |
$402.66 |
1996 |
$477.59 |
1997 |
$560.88 |
1998 |
$657.06 |
1999 |
$895.13 |
If you held the bond all of 2000, reduce the total OID for that
year, $994.92 (as determined in Example 10), by the
allocable part of the acquisition premium for 2000, $100.07 ($.27341
x 366 days). The difference, $894.85, is the total OID to
include in income for 2000.
Example 12.
Assume the same facts as Example 11, except that you
bought the bond for $90,102.83. In this case, you bought the bond for
an amount equal to the original issue price plus accumulated OID.
Therefore, you did not pay an acquisition premium. You would have
included $79.07 ($.32274 x 245 days) in income for 1984. For the
remaining years, you would have included the amounts figured in
Example 10.
Example 13.
Assume the same facts as Example 11, except that you
bought the bond for $89,500. You did not pay an acquisition premium
because your cost was less than the adjusted issue price. You must
include in income each year the amounts figured in Example 12.
The bonds have market discount, which must be reported under the
rules explained in chapter 1 of Publication 550.
Acquisition premium on debt instruments purchased after July
18, 1984.
If you bought the debt instrument at an acquisition premium after
July 18, 1984, figure the reduction of OID includible in income by
reducing the daily OID by the daily acquisition premium. However, the
method of figuring the daily acquisition premium is different from the
method described in the preceding discussion. To figure the daily
acquisition premium under this method, you multiply the daily OID by
the following fraction.
- The numerator is the total acquisition premium.
- The denominator is the total OID remaining for the
instrument after your purchase date.
Example 14.
Assume the same facts as Example 9, except that you
bought the bond for $99,000 on August 1, 2000, after its original
issue on August 1, 1983. In this case, you paid more for the bond than
its $96,413.64 adjusted issue price ($90,000 + $6,413.64 accrued OID).
You paid $2,586.36 ($99,000 - $96,413.64) acquisition premium.
The daily OID as reduced for the acquisition premium for the accrual
period August 1, 2000, to July 31, 2001, is figured as follows:
1) |
Daily OID on date of purchase (18th accrual
period) |
$2.83992* |
2) |
Acquisition premium |
$2,586.36 |
3) |
Total OID remaining after purchase date
($10,000 - $6,413.64) |
3,586.36 |
4) |
Line 2 x line 3 |
| 0.72117 |
5) |
Line 1 x line 4 |
2.04807 |
6) |
Daily OID reduced for the acquisition
premium. Line 1 - line 5 |
$0.79185 |
(* As shown in Example
9.) |
The total OID to include in income for 2000 (August 1 -
December 31) is $121.15 ($0.79185 x 153 days).
If you hold the bond for all of 2001, multiply the total OID for
the year by 2.04807 and subtract the result from the total OID. The
reduced amount is the total OID to be included in income for 2001.
Using Section I-A to figure accumulated OID.
If you bought your corporate debt instrument in 2000 or 2001 and it
is listed in Section I-A, you can figure the
accumulated OID to the date of purchase by adding the following
amounts.
- The amount from the "Total OID to January 1, 2000"
column for your debt instrument.
- The OID from January 1, 2000, to the date of purchase,
figured as follows.
- Multiply the daily OID for the first accrual period in 2000
by the number of days from January 1 to the date of purchase, or the
end of the accrual period if the instrument was purchased in the
second or third accrual period.
- Multiply the daily OID for each subsequent accrual period by
the number of days in the period to the date of purchase or the end of
the accrual period, whichever applies.
- Add the amounts figured in (2a) and (2b).
Debt Instruments Issued
After 1984
If you hold debt instruments issued after 1984, you must report
part of the discount in gross income each year that you own the
instruments. You must include the OID in gross income whether or not
you hold the instrument as a capital asset. Your basis in the
instrument is increased by the OID you include in income. For
information about showing the correct OID on your tax return, see
How To Report OID, earlier.
Form 1099-OID.
You should receive a Form 1099-OID showing OID for the part
of 2000 you held the bond. However, if you paid an acquisition
premium, you may need to refigure the OID to report on your tax
return. See Figuring OID using the constant yield method
and Acquisition premium, later.
You may also need to refigure the OID for a contingent payment or
inflation-indexed debt instrument on which the amount reported on Form
1099-OID is inaccurate. See Contingent Payment Debt
Instruments or Inflation-Indexed Debt Instruments,
later.
Form 1099-OID not received.
If you held an OID instrument in 2000 but did not receive a Form
1099-OID, refer to Section I-B later in this
publication. The OID listed is for each $1,000 of redemption price.
You must adjust the listed amount if your debt instrument has a
different principal amount. For example, if you have an instrument
with a $500 principal amount, use one-half of the listed amount to
figure your OID.
Use the OID shown in Section I-B for the calendar
year if you held the instrument the entire year. (If your instrument
is not listed in Section I-B, consult the issuer for
information about the issue price, yield to maturity, and the OID that
accrued for 2000.) If you did not hold the debt instrument the entire
year, figure your OID as follows.
- Look up the daily OID amount for the first 2000 accrual
period in which you held the instrument. (See Accrual period
under Figuring OID using the constant yield method,
next.)
- Multiply the daily OID amount by the number of days in 2000
you held the instrument during that accrual period.
- Repeat (1) and (2) for any remaining 2000 accrual periods in
which you held the instrument.
- Add the results of (2) and (3). This is the OID to include
in income for 2000, unless you paid an acquisition premium. (The
reduction for acquisition premium is discussed later.)
Tax-exempt bond.
If you own a tax-exempt bond, figure your basis in the bond by
adding to your cost the OID you would have included in income if the
bond had been taxable. You need to make this adjustment to determine
if you have a gain or loss on a later disposition of the bond. Use the
rules that follow to determine your OID.
Figuring OID using the constant yield method.
This discussion shows how to figure OID on debt instruments issued
after 1984 using a constant yield method. (The special rules that
apply to contingent payment debt instruments and inflation-indexed
debt instruments are explained later.) OID is allocated over the life
of the instrument through adjustments to the issue price for each
accrual period.
Figure the OID allocable to any accrual period as follows.
- Multiply the adjusted issue price at the beginning of the
accrual period by a fraction. The numerator of the fraction is the
instrument's yield to maturity and the denominator is the number of
accrual periods per year. The yield must be stated appropriately
taking into account the length of the particular accrual
period.
- Subtract from the result in (1) any qualified stated
interest allocable to the accrual period.
Accrual period.
For debt instruments issued after 1984 and before April 4, 1994, an
accrual period is each 6-month period that ends on the day that
corresponds to the stated maturity date of the debt instrument or the
date 6 months before that date. For example, a debt instrument
maturing on March 31 has accrual periods that end on September 30 and
March 31 of each calendar year. Any short period is included as the
first accrual period.
For debt instruments issued after April 3, 1994, accrual
periods may be of any length and may vary in length over the term of
the instrument, as long as each accrual period is no longer than one
year and all payments are made on the first or last day of an accrual
period. However, the OID listed for these debt instruments in
Section I-B has been figured using 6-month accrual
periods.
Daily OID.
The OID for any accrual period is allocated ratably to each day in
the accrual period. Figure the amount to include in income by adding
the OID for each day that you hold the debt instrument during the
year. Since your tax year will usually overlap more than one accrual
period, you must include the proper daily OID for each accrual period
that falls within or overlaps your tax year. If your debt instrument
has 6-month accrual periods, your tax year will usually include one
full 6-month accrual period and parts of two other 6-month periods.
Figuring daily OID.
The daily OID for the initial accrual period is figured
using the following formula.
ip |
= |
issue price |
ytm |
= |
yield to maturity |
n |
= |
number of accrual periods in one year |
qsi |
= |
qualified stated interest |
p |
= |
number of days in accrual period |
The daily OID for subsequent accrual periods is figured
the same way except that the adjusted issue price at the beginning of
each period is used in the formula instead of the issue price.
Example 15.
On January 1, 2000, you bought a 15-year, 10% bond of A Corporation
at original issue for $86,235.17. According to the prospectus, the
bond matures on December 31, 2014, at a stated redemption price of
$100,000. The yield to maturity is 12%, compounded semiannually. The
bond provides for qualified stated interest payments of $5,000 on June
30 and December 31 of each calendar year. The accrual periods are the
6-month periods ending on each of these dates. The daily OID for the
first accrual period is figured as follows:
The adjusted issue price at the beginning of the second accrual
period is the issue price plus the OID previously includible in income
($86,235.17 + $174.11), or $86,409.28. The daily OID for the second
accrual period is:
Since the first and second accrual periods coincide exactly with
your tax year, you include in income for 2000 the OID allocable to the
first two accrual periods, $174.11 ($.95665 x 182 days) plus
$184.56 ($1.00303 x 184 days), or $358.67. Add the OID to the
$10,000 interest you report in 2000.
Example 16.
Assume the same facts as Example 15, except that you
bought the bond at original issue on May 1, 2000. Also, the interest
payment dates are October 31 and April 30 of each calendar year. The
accrual periods are the 6-month periods ending on each of these dates.
The daily OID for the first accrual period (May 1, 2000 -
October 31, 2000) is figured as follows:
The daily OID for the second accrual period (November 1, 2000
- April 30, 2001) is:
If you hold the bond through the end of 2000, you must include
$236.31 of OID in income. This is $174.11 ($.94625 x 184 days)
for the period May 1 through October 31 plus $62.20 ($1.01967 x
61 days) for the period November 1 through December 31. The OID is
added to the $5,000 interest income paid on October 31, 2000. Your
basis in the bond is increased by the OID you include in income. On
January 1, 2001, your basis in the A Corporation bond is $86,471.48
($86,235.17 + $236.31).
Short first accrual period.
You may have to make adjustments if a debt instrument has a short
first accrual period. For example, a debt instrument with 6-month
accrual periods that is issued on February 15 and matures on October
31 has a short first accrual period that ends April 30. (The remaining
accrual periods begin on May 1 or November 1.) For this short period,
figure the daily OID as described earlier, but adjust the yield for
the length of the short accrual period. You may use any reasonable
compounding method in determining OID for a short period. Examples of
reasonable compounding methods include continuous compounding and
monthly compounding (that is, simple interest within a month). Consult
your tax advisor for more information about making this computation.
The OID for the final accrual period is the excess of
the amount payable at maturity (other than a payment of qualified
stated interest) over the adjusted issue price at the beginning of the
final accrual period.
Acquisition premium.
If you bought the debt instrument at an acquisition premium,
multiply the daily OID by the following fraction to figure the daily
acquisition premium that reduces the daily OID.
- The numerator is the acquisition premium.
- The denominator is the total OID remaining for the
instrument after your purchase date.
Example 17.
Assume the same facts as Example 16, except that you
bought the bond on November 1, 2000, for $87,000, after its original
issue on May 1, 2000. The adjusted issue price on November 1, 2000, is
$86,409.28 ($86,235.17 + $174.11). Under these assumptions, you
purchased the bond at an acquisition premium of $590.72 (your cost,
$87,000, less the adjusted issue price, $86,409.28) and you must
reduce the daily OID for any day you hold the bond.
The daily OID for the accrual period November 1, 2000, through
April 30, 2001, as reduced for the acquisition premium, is figured as
follows:
1) |
Daily OID on date of purchase (2nd accrual
period) |
$1.01967* |
2) |
Acquisition premium |
$590.72 |
3) |
Total OID remaining after purchase date
($13,764.83 - $174.11) |
13,590.72 |
4) |
Line 2 x line 3 |
.04346 |
5) |
Line 1 x line 4 |
.04431 |
6) |
Daily OID reduced for the acquisition
premium. Line 1 - line 5 |
$0.97536 |
(* As shown in Example
16.) |
The total OID to include in income for 2000 is $59.50 ($.97536
x 61 days).
Contingent Payment Debt Instruments
This discussion shows how to figure OID on a contingent payment
debt instrument issued after August 12, 1996, that was issued for cash
or publicly traded property. In general, a contingent payment
debt instrument is a debt instrument that provides for one or
more payments that are contingent as to timing or amount. If you hold
a contingent payment debt instrument, you must report OID as it
accrues each year.
Because the actual payments on a contingent payment debt instrument
cannot be known in advance, issuers and holders cannot use the
constant yield method (discussed earlier under Debt Instruments
Issued After 1984) without making certain assumptions about the
payments on the debt instrument. To figure OID accruals on contingent
payment debt instruments, holders and issuers must use the
noncontingent bond method.
Noncontingent bond method.
Under this method, the issuer must construct a hypothetical
noncontingent bond that has terms and conditions similar to the
contingent payment debt instrument. The issuer constructs the payment
schedule of the hypothetical noncontigent bond by projecting a fixed
amount for each contingent payment. Holders and issuers accrue OID on
this hypothetical noncontingent bond using the constant yield method
that applies to fixed payment debt instruments. When a contingent
payment differs from the projected fixed amount, the holders and
issuers make adjustments to their OID accruals. If the actual
contingent payment is larger than expected, both the issuer and the
holder increase their OID accruals. If the actual contingent payment
is smaller than expected, holders and issuers generally decrease their
OID accruals.
Form 1099-OID.
The amount shown in box 1 of the Form 1099-OID you receive
for a contingent payment debt instrument may not be the correct amount
to include in income. For example, the amount may not be correct if
the contingent payment was different from the projected amount. If the
amount in box 1 is not correct, you must figure the OID to report on
your return under the following rules. For information on showing an
OID adjustment on your tax return, see How To Report OID,
earlier.
Figuring OID.
To figure OID on a contingent payment debt instrument, you need to
know the "comparable yield" and "projected payment schedule"
of the debt instrument. The issuer must make these available to you.
Comparable yield.
The comparable yield is the yield on the hypothetical noncontingent
bond that the issuer determines and constructs at the time of
issuance.
Projected payment schedule.
The projected payment schedule is the payment schedule of the
hypothetical noncontingent bond. The schedule includes all fixed
payments due under the contingent payment debt instrument and a
projected fixed amount for each contingent payment. The projected
payment schedule is created by the issuer. It is used to determine the
holder's interest accruals and adjustments.
Steps for figuring OID.
Figure the OID on a contingent payment debt instrument in two
steps.
- Figure the OID on the hypothetical noncontingent bond using
the constant yield method (discussed earlier under Debt
Instruments Issued After 1984) that applies to fixed payment
debt instruments. Use the comparable yield as the yield to maturity.
Use the projected payment schedule to determine the hypothetical
bond's adjusted issue price at the beginning of the accrual period. Do
not treat any amount payable as qualified stated interest.
- Adjust the OID in (1) to account for actual contingent
payments. If the contingent payment is greater than the projected
fixed amount, you have a positive adjustment. If the contingent
payment is less than the projected fixed amount, you have a negative
adjustment.
Net positive adjustment.
A net positive adjustment exists when the total of any positive
adjustments described in (2) above exceeds the total of any negative
adjustments. Treat a net positive adjustment as additional OID for the
tax year.
Net negative adjustment.
A net negative adjustment exists when the total of any negative
adjustments described in (2) above exceeds the total of any positive
adjustments. Use a net negative adjustment to offset OID on the debt
instrument for the tax year. If the net negative adjustment exceeds
the OID on the debt instrument for the tax year, you can claim the
excess as an ordinary loss. However, the amount you can claim as an
ordinary loss is limited to the OID on the debt instrument you
included in income in prior tax years. You must carry forward any
excess net negative adjustment and treat it as a negative adjustment
in the next tax year.
Basis adjustments.
In general, increase your basis in a contingent payment debt
instrument by the OID included in income. Your basis, however, is not
affected by any negative or positive adjustments. Decrease your basis
by any noncontigent payment received and the projected contingent
payment scheduled to be received.
Treatment of gain or loss on sale or exchange.
If you sell a contingent payment debt instrument at a gain, your
gain is ordinary income (interest income), even if you hold the
instrument as a capital asset. If you sell a contingent payment debt
instrument at a loss, your loss is an ordinary loss to the extent of
your prior OID accruals on the instrument. If your loss exceeds your
prior OID accruals and the instrument is a capital asset, treat the
excess loss as a capital loss.
See section 1.1275-4 of the regulations for exceptions to
these rules.
Premium, acquisition, and market discount.
The rules for accruing premium, acquisition premium, and market
discount do not apply to a contingent payment debt instrument. See
section 1.1275-4 of the regulations to determine how to account
for these items.
Inflation-Indexed Debt Instruments
This discussion shows how you figure OID on certain
inflation-indexed debt instruments issued after January 5, 1997. An
inflation-indexed debt instrument is generally a debt
instrument on which the payments are adjusted for inflation and
deflation (such as Treasury inflation-indexed securities).
In general, if you hold an inflation-indexed debt instrument, you
must report as OID any increase in the inflation-adjusted principal
amount of the instrument that occurs while you held the instrument
during the tax year. You must include the OID in gross income whether
or not you hold the instrument as a capital asset. Your basis in the
instrument is increased by the OID you include in income.
Inflation-adjusted principal amount.
For any date, the inflation-adjusted principal amount of an
inflation-indexed debt instrument is the product of the following.
- The instrument's outstanding principal amount (determined as
if there were no inflation or deflation over the term of the
instrument), multiplied by
- The index ratio for that date.
Index ratio.
This is a fraction, the numerator of which is the value of the
reference index for the date and the denominator of which is the value
of the reference index for the instrument's issue date.
A qualified reference index measures inflation and
deflation over the term of a debt instrument. Its value is reset each
month to a current value of a single qualified inflation index (for
example, the nonseasonally adjusted U.S. City Average All Items
Consumer Price Index for All Urban Consumers (CPI-U), published by the
Bureau of Labor Statistics of the Department of Labor). The value of
the index for any date between reset dates is determined through
straight-line interpolation.
The daily index ratios for Treasury inflation-indexed securities
are available on the Internet at: www.publicdebt.treas.gov.
Form 1099-OID.
The amount shown in box 6 of the Form 1099-OID you receive
for an inflation-indexed debt instrument may not be the correct amount
to include in income. For example, the amount may not be correct if
you bought the debt instrument (other than at original issue) or sold
it during the year. If the amount shown in box 6 is not correct, you
must figure the OID to report on your return under the following
rules. For information about showing an OID adjustment on your tax
return, see How To Report OID, earlier.
Figuring OID.
Figure the OID on an inflation-indexed debt instrument using one of
the following methods.
- The coupon bond method, described in the
following discussion, applies if the instrument is issued at par, all
stated interest payable on the instrument is qualified stated
interest, and the coupons have not been stripped from the instrument.
This method generally applies, for example, to Treasury
inflation-indexed securities.
- The discount bond method applies to any
inflation-indexed debt instrument that does not qualify for the coupon
bond method, such as a stripped instrument. This method is described
in section 1.1275-7(e) of the regulations.
Under the coupon bond method, figure the OID you must report
for the tax year as follows.
Debt instrument held at the end of the tax year.
If you held the debt instrument at the end of the tax year, your
OID for the year is:
- The inflation-adjusted principal amount for the first day on
which you held the instrument during the tax year, minus
- The total of the following amounts.
- The inflation-adjusted principal amount for the day after
the last day of the tax year.
- Any principal payments you received during the year.
Debt instrument sold or retired during the tax year.
If you sold the debt instrument during the tax year, or if it was
retired, your OID for the year is:
- The inflation-adjusted principal amount for the first day on
which you held the instrument during the tax year, minus
- The total of the following amounts.
- The inflation-adjusted principal amount for the last day on
which you held the instrument during the tax year.
- Any principal payments you received during the year.
Example 18.
On February 6, 2000, you bought a 10-year, 3.375% inflation-indexed
debt instrument for $9,831. The stated principal amount is $10,000 and
the inflation-adjusted principal amount for February 6, 2000, is
$10,010.40. You held the debt instrument until September 1, 2000, when
the inflation-adjusted principal amount was $10,116.50. Your OID for
the 2000 tax year is $106.10 ($10,116.50 - $10,010.40). Your
basis in the debt instrument on September 1, 2000, was $9,937.10
($9,831 cost + $106.10 OID for 2000).
Stated interest.
Under the coupon bond method, you report any stated interest on the
debt instrument under your regular method of accounting. For example,
if you use the cash method, you generally include in income for the
tax year any interest payments received on the instrument during the
year.
Deflation adjustments.
If your calculation to figure OID on an inflation-indexed debt
instrument produces a negative number, you do not have any OID.
Instead, you have a deflation adjustment. A deflation adjustment
generally is used to offset interest income from the debt instrument
for the tax year. This offset is shown as an adjustment on your
Schedule B (Form 1040), in the same manner as that used to show an OID
adjustment. See How To Report OID, earlier.
You decrease your basis in the debt instrument by the deflation
adjustment used to offset interest income.
Example 19.
Assume the same facts as Example 18, except that you
bought the instrument on July 1, 2000, when the inflation-adjusted
principal amount was $10,111.40, and sold the instrument on August 1,
2000, when the inflation-adjusted principal amount was $10,105.10.
Because the OID calculation for 2000 ($10,105.10 - $10,111.40)
produces a negative number (negative $6.30), you have a deflation
adjustment. You use this deflation adjustment to offset the stated
interest reported to you on the debt instrument.
Your basis in the debt instrument on August 1, 2000, is $9,824.70
($9,831 cost - $6.30 deflation adjustment for 2000).
Premiums on inflation-indexed debt instruments.
In general, any premium on an inflation-indexed debt instrument is
determined, as of the date you acquire the instrument, by assuming
that there will be no further inflation or deflation over the
remaining term of the instrument. You allocate any premium over the
remaining term of the instrument by making the same assumption. In
general, the premium allocable to a tax year offsets the interest
otherwise includible in income for the year. If there is any excess
allocable to the year, this excess generally offsets the OID on the
instrument for the year.
Figuring OID on Stripped Bonds and Coupons
If you strip one or more coupons from a bond and then sell or
otherwise dispose of the bond or the stripped coupons, they are
treated as separate debt instruments issued with OID. The holder of a
stripped bond has the right to receive the principal (redemption
price) payment. The holder of a stripped coupon has the right to
receive an interest payment on the bond. The rule requiring the holder
of a debt instrument issued with OID to include the OID in gross
income as it accrues applies to stripped bonds and coupons acquired
after July 1, 1982. See Bonds and Coupons Purchased After July 1,
1982, and Before 1985 or Bonds and Coupons Purchased After
1984, later, for information about figuring the OID to report.
Stripped bonds and coupons include:
- Zero coupon instruments available through the Department of
the Treasury's STRIPS program and government-sponsored enterprises
such as the Resolution Funding Corporation and the Financing
Corporation.
- Instruments backed by U.S. Treasury securities that
represent ownership interests in those securities. Examples include
obligations backed by U.S. Treasury bonds that are offered primarily
by brokerage firms (variously called CATS, TIGRs, etc.).
Seller of stripped bond or coupon.
If you strip coupons from a bond and sell the bond or coupons,
include in income the interest that accrued while you held the bond
before the date of sale, to the extent the interest was not previously
included in your income. For an obligation acquired after October 22,
1986, you must also include the market discount that accrued before
the date of sale of the stripped bond (or coupon) to the extent the
discount was not previously included in your income.
Add the interest and market discount you include in income to the
basis of the bond and coupons. This adjusted basis is then allocated
between the items you keep and the items you sell, based on the fair
market value of the items. The difference between the sale price of
the bond (or coupon) and the allocated basis of the bond (or coupon)
is the gain or loss from the sale.
Treat any item you keep as an OID bond originally issued and
purchased by you on the sale date of the other items. If you keep the
bond, treat the excess of the redemption price of the bond over the
basis of the bond as the OID. If you keep the coupons, treat the
excess of the amount payable on the coupons over the basis of the
coupons as the OID.
Purchaser of stripped bond or coupon.
If you purchase a stripped bond or coupon, treat it as if it were
originally issued on the date of purchase. If you purchase the
stripped bond, treat as OID any excess of the stated redemption price
at maturity over your purchase price. If you purchase the stripped
coupon, treat as OID any excess of the amount payable on the due date
of the coupon over your purchase price.
Form 1099-OID
The amount shown in box 6 of the Form 1099-OID you receive
for a stripped bond or coupon may not be the proper amount to include
in income. If not, you must figure the OID to report on your return
under the rules that follow. For information about showing an OID
adjustment on your tax return, see How To Report OID,
earlier.
Tax-Exempt Bonds and Coupons
The OID on a stripped tax-exempt bond, or on a stripped coupon from
such a bond, is generally not taxable. However, if you acquired the
stripped bond or coupon after October 22, 1986, you must accrue OID on
it to determine its basis when you dispose of it. How you figure
accrued OID and whether any OID is taxable depend on the date you
bought (or are treated as having bought) the stripped bond or coupon.
Acquired before June 11, 1987.
None of the OID on bonds or coupons acquired before this date is
taxable. The accrued OID is added to the basis of the bond or coupon.
The accrued OID is the amount that produces a yield to maturity (YTM),
based on your purchase date and purchase price, equal to the lower of
the following rates.
- The coupon rate on the bond before the separation of
coupons.
- The YTM of the stripped bond or coupon.
If you can establish the YTM of the bond (with all coupons
attached) at the time of its original issue, you may use that YTM
instead of the coupon rate in (1) above.
Increase your basis in the stripped tax-exempt bond or coupon by
the interest that accrued but was neither paid nor previously
reflected in your basis before the date you sold the bond or coupon.
Acquired after June 10, 1987.
Part of the OID on bonds or coupons acquired after this date may be
taxable. Figure the taxable part in three steps.
Step 1 -- Figure OID as if all taxable.
First figure the OID following the rules in this section as if all
the OID were taxable. (See Bonds and Coupons Purchased After
1984, later.) Use the yield to maturity (YTM) based on the date
you obtained the stripped bond or coupon.
Step 2 -- Determine nontaxable part.
Find the issue price that would produce a YTM as of the purchase
date equal to the lower of the following rates.
- The coupon rate on the bond from which the coupons were
separated.
- The YTM based on the purchase price of the stripped coupon
or bond.
You can choose to use the original YTM instead of the coupon
rate of the bond in (1) above.
Subtract this issue price from the stated redemption price of the
bond at maturity (or, in the case of a coupon, the amount payable on
the due date of the coupon). The result is the part of the OID treated
as OID on a stripped tax-exempt bond or coupon.
Step 3 -- Determine taxable part.
The taxable part of OID is the excess of the OID determined in
Step 1 over the nontaxable part determined in Step 2.
Exception.
None of the OID on your stripped tax-exempt bond or coupon is
taxable if you bought it from a person who held it for sale on June
10, 1987, in the ordinary course of that person's trade or business.
Basis adjustment.
Increase the basis in your stripped tax-exempt bond or coupon by
the taxable and nontaxable accrued OID. If you own a tax-exempt bond
from which one or more coupons have been stripped, increase your basis
in it by the sum of the interest accrued but not paid before you
dispose of it (and not previously reflected in basis) and any accrued
market discount to the extent not previously included in your income.
Example 20.
Assume that a tax-exempt bond with a face amount of $100 due
January 1, 2002, and a coupon rate of 10% (compounded semiannually)
was issued for $100 on January 1, 1999. On January 1, 2000, the bond
was stripped and you bought the right to receive the principal amount
for $79.21. The stripped bond is treated as if it were originally
issued on January 1, 2000, with OID of $20.79 ($100.00 -
$79.21). This reflects a YTM at the time of the strip of 12%
(compounded semiannually). The tax-exempt part of OID on the stripped
bond is limited to $17.73. This is the difference between the
redemption price ($100) and the issue price that would produce a YTM
of 10% ($82.27). This part of the OID is treated as OID on a
tax-exempt obligation.
The OID on the stripped bond that is more than the tax-exempt part
is $3.06. This is the excess of the total OID ($20.79) over the
tax-exempt part ($17.73). This part of the OID ($3.06) is treated as
OID on an obligation that is not tax exempt.
The total OID allocable to the accrual period ending June 30, 2000,
is $4.75 (6% x $79.21). Of this, $4.11 (5% x $82.27) is
treated as OID on a tax-exempt obligation and $0.64 ($4.75 -
$4.11) is treated as OID on an obligation that is not tax exempt. Your
basis in the bond is increased to $83.96 ($79.21 issue price + accrued
OID of $4.75).
Bonds and Coupons Purchased After July 1, 1982, and Before
1985
If you purchased a stripped bond or coupon after July 1, 1982, and
before 1985, and you held that debt instrument as a capital asset
during any part of 2000, you must figure the OID to be included in
income using a constant yield method. Under this method,
OID is allocated over the time you hold the debt instrument by
adjusting the acquisition price for each accrual period. The OID for
the accrual period is figured by multiplying the adjusted acquisition
price at the beginning of the period by the yield to maturity.
Adjusted acquisition price.
The adjusted acquisition price of a stripped bond or coupon at the
beginning of the first accrual period is its purchase (or acquisition)
price. The adjusted acquisition price at the beginning of any
subsequent accrual period is the sum of the acquisition price and all
of the OID includible in income before that accrual period.
Accrual period.
An accrual period for any stripped bond or coupon acquired before
1985 is each one-year period beginning on the date of the purchase of
the obligation and each anniversary thereafter, or the shorter period
to maturity for the last accrual period.
Yield to maturity (YTM).
In general, the yield to maturity of a stripped bond or coupon is
the discount rate that, when used in figuring the present value of all
principal and interest payments, produces an amount equal to the
acquisition price of the bond or coupon.
Figuring YTM.
If you purchased a stripped bond or coupon after July 1, 1982, but
before 1985, and the period from your purchase date to the day the
instrument matures can be divided exactly into full one-year periods
without including a shorter period, then the YTM can be figured by
applying the following formula:
srp |
= |
stated redemption price at maturity |
ap |
= |
acquisition price |
m |
= |
number of full accrual periods from purchase to
maturity |
If the instrument is a stripped coupon, the stated redemption price
is the amount payable on the due date of the coupon. See Example
21.
If the period between your purchase date and the maturity date (or
due date) of the instrument does not divide into an exact number of
full one-year periods, so that a period shorter than one year must be
included, consult your broker or your tax advisor for information
about figuring the YTM.
Example 21.
On November 15, 1984, you bought a coupon stripped from a U.S.
Treasury bond through the Department of the Treasury's STRIPS program
for $20,000. An amount of $100,000 is payable on the coupon's due
date, November 14, 2009. There are exactly 25 one-year periods between
the purchase date, November 15, 1984, and the coupon's due date,
November 14, 2009. Your YTM on this stripped coupon is figured as
follows:
Use 6.649% YTM to figure the OID for each accrual period or partial
accrual period for which you must report OID.
Daily OID.
The OID for any accrual period is allocated ratably to each day in
the accrual period. You figure the amount to include in income by
adding the daily OID amounts for each day you hold the debt instrument
during the year. If your tax year overlaps more than one accrual
period (which will be the case unless the accrual period coincides
with your tax year), you must include the proper daily OID amounts for
each of the two accrual periods.
The daily OID for the initial accrual period is figured
by applying the following formula:
ap |
= |
acquisition price |
ytm |
= |
yield to maturity |
p |
= |
number of days in accrual period |
The daily OID for subsequent accrual periods is computed
in the same way except the adjusted acquisition price at the beginning
of each period is used in the formula instead of the acquisition
price.
The rules for figuring OID on these instruments are similar to
those illustrated in Example 9 and Example 10,
earlier, under Debt Instruments Issued After July 1, 1982,
and Before 1985.
Bonds and Coupons Purchased After 1984
If you purchased a stripped bond or coupon (other than a stripped
inflation-indexed instrument) after 1984, and you held that debt
instrument during any part of 2000, you must compute the OID to be
included in income using a constant yield method. Under
this method, OID is allocated over the time you hold the debt
instrument by adjusting the acquisition price for each accrual period.
The OID for the accrual period is figured by multiplying the adjusted
acquisition price at the beginning of the period by a fraction. The
numerator of the fraction is the instrument's yield to maturity and
the denominator is the number of accrual periods per year.
If the stripped bond or coupon is an inflation-indexed instrument,
you must figure the OID to be included in income using the discount
bond method described in section 1.1275(e) of the regulations.
Adjusted acquisition price.
The adjusted acquisition price of a stripped bond or coupon at the
beginning of the first accrual period is its purchase (or acquisition)
price. The adjusted acquisition price at the beginning of any
subsequent accrual period is the sum of the acquisition price and all
of the OID includible in income before that accrual period.
Accrual period.
For a stripped bond or coupon acquired after 1984 and before April
4, 1994, an accrual period is each 6-month period that ends on the day
that corresponds to the stated maturity date of the stripped bond (or
payment date of a stripped coupon) or the date 6 months before that
date. For example, a stripped bond that has a maturity date (or a
stripped coupon that has a payment date) of March 31 has accrual
periods that end on September 30 and March 31 of each calendar year.
Any short period is included as the first accrual period.
For a stripped bond or coupon acquired after April 3, 1994, accrual
periods may be of any length and may vary in length over the term of
the instrument, as long as each accrual period is no longer than one
year and all payments are made on the first or last day of an accrual
period.
Yield to maturity (YTM).
In general, the yield to maturity of a stripped bond or coupon is
the discount rate that, when used in figuring the present value of all
principal and interest payments, produces an amount equal to the
acquisition price.
Figuring YTM.
How you figure the YTM for a stripped bond or coupon purchased
after 1984 depends on whether you have equal accrual periods or a
short initial accrual period.
1) Equal accrual periods.
If the period from the date you purchased a stripped bond or coupon
to the maturity date can be divided evenly into full accrual periods
without including a shorter period, then you can figure the YTM by
using the following formula:
n |
= |
number of accrual periods in one year |
srp |
= |
stated redemption price at maturity |
ap |
= |
acquisition price |
m |
= |
number of full accrual periods from purchase to
maturity |
If the instrument is a stripped coupon, the stated redemption price
is the amount payable on the due date of the coupon.
Example 22.
On May 15, 1989, you bought a coupon stripped from a U.S. Treasury
bond through the Department of the Treasury's STRIPS program for
$38,000. An amount of $100,000 is payable on the coupon's due date,
November 14, 2001. There are exactly twenty-five 6-month periods
between the purchase date, May 15, 1989, and the coupon's due date,
November 14, 2001. The YTM on this stripped coupon is figured as
follows.
Use 7.892% YTM to figure the OID for each accrual period or partial
accrual period for which you must report OID.
2) Short initial accrual period.
If the period from the date you purchased a stripped bond or coupon
to the date of its maturity cannot be divided evenly into full accrual
periods, so that a shorter period must be included, you can figure the
YTM by using the following formula (the exact method):
n |
= |
number of accrual periods in one year |
srp |
= |
stated redemption price at maturity |
ap |
= |
acquisition price |
r |
= |
number of days from purchase to end of short accrual
period |
s |
= |
number of days in accrual period ending on last day of
short accrual period |
m |
= |
number of full accrual periods from purchase to
maturity |
Example 23.
On June 2, 2000, you bought a coupon stripped from a U.S. Treasury
bond through the Department of the Treasury's STRIPS program for
$60,000. An amount of $100,000 is payable on the coupon's due date,
August 14, 2006. You decide to figure OID using 6-month accrual
periods. There are 12 full 6-month accrual periods and a 74-day short
initial accrual period from the purchase date to the coupon's due
date. The YTM on this stripped coupon is figured as follows.
Use 8.406% YTM to figure the OID for each accrual period or partial
accrual period for which you must report OID.
Daily OID.
The OID for any accrual period is allocated ratably to each day in
the accrual period. You must include in income the sum of the daily
OID amounts for each day you hold the debt instrument during the year.
Since your tax year will usually overlap more than one accrual period,
you must include the proper daily OID amounts for each accrual period
that falls within or overlaps your tax year.
Figuring daily OID.
For the initial accrual period of a stripped bond or
coupon acquired after 1984, figure the daily OID using Formula 1,
next, if there are equal accrual periods. Use Formula 2
if there is a short initial accrual period.
For subsequent accrual periods, figure the daily OID
using Formula 1 (whether or not there was a short initial
accrual period), except use the adjusted acquisition price in the
formula instead of the acquisition price.
Formula 1 --
Formula 2 --
ap |
= |
acquisition price |
ytm |
= |
yield to maturity |
n |
= |
number of accrual periods in one year |
p |
= |
number of days in accrual period |
r |
= |
number of days from purchase to end of short accrual
period |
s |
= |
number of days in accrual period ending on last day of
short accrual period |
The rules for figuring OID on these instruments are similar to
those illustrated in Example 15 and Example 16,
earlier, under Debt Instruments Issued After 1984.
Example 24.
Assume the same facts as Example 23, and you held the
coupon for the rest of 2000. The daily OID amounts are figured as
follows:
For the short initial accrual period from June 2, 2000, through
August 14, 2000 (using Formula 2), the daily OID equals:
For the second accrual period from August 15, 2000, through
February 14, 2001 (using Formula 1), the daily OID equals:
The adjusted acquisition price of $61,018.20 in this accrual period
is the original $60,000 acquisition price plus $1,018.20 OID for the
short initial accrual period (figured in step (1) of the following
computation).
The OID to be reported on your 2000 tax return is figured as
follows:
1) |
OID for first accrual period:
$13.75946 x 74 days
(June 2 - August 14) |
= |
$1,018.20 |
2) |
OID for second accrual period:
$13.93802 x 139 days
(August 15 - December 31) |
= |
1,937.38 |
3) |
Total OID to report on 2000 tax return (line 1
+ line 2) |
| $2,955.58 |
The rules for figuring OID on these instruments are similar to
those illustrated in Example 15 and Example 16,
earlier, under Debt Instruments Issued After 1984.
Final accrual period. The OID for the final accrual period for a stripped bond or coupon
is the excess of the amount payable at maturity of the stripped bond
(or interest payable on the stripped coupon) over the adjusted
acquisition price at the beginning of the final accrual period. The
daily OID for the final accrual period is computed by dividing the OID
for the period by the number of days in the period.
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