Exotic coupon stripping: a voyage to the frontier between debt and option
Article Abstract:
Coupon stripping transactions raise issues concerning the distinction between debt and option in federal income tax law. These transactions involve separating ownership of principal from ownership rights to interest payments on a debt instrument. Coupon stripping brings up two basic tax issues. First, the transaction must be structured so that either no separate entity is created or the entity is given pass-through treatment for tax purposes. The second tax issue concerns income recognition timing. A modified bifurcation approach, which separates variable strips into three types for federal income tax treatment, is the recommended approach for these transactions.
Publication Name: Virginia Tax Review
Subject: Law
ISSN: 0735-9004
Year: 1993
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If not now, when? And if not thisphrase, whichphrase?
Article Abstract:
President Clinton used the phrase 'sooner rather than later' during a visit by Yasir Arafat in early 1998, and that phrase has crept into political and social language across the country. It is often said in one continuous breath, and is sometimes even used as an adjective. The world 'globality' was introduced during last year's World Economic Forum as a term to describe the condition that exists after globalization.
Publication Name: The New York Times Magazine
Subject:
ISSN: 0028-7822
Year: 1999
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Spookspeak in Deutchland
Article Abstract:
The jargon of the Central Intelligence Agency is unchanged although politics change. A sampling of various CIA acronyms is provided. A 1929 use of the term 'rap' is found in a quote from Damon Runyon. A 1933 quote from Winston Churchill also contains a reference to the term, meaning 'speak easily'.
Publication Name: The New York Times Magazine
Subject:
ISSN: 0028-7822
Year: 1995
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