The Tax Reform Act of 1984 made substantial revisions to the original issue discount provisions of the Internal Revenue Code. The most significant change to the OID rules is the effect it will have on debt instruments given in consideration for the sale or exchange of property. This article explains and analyzes the new OID rules with respect to property transfers and provides the practitioner with a methodology for identifying transactions that may be subject to the recently enacted OID provisions.
REV. OF TAX'N OF INDIVIDUALS
Christine Dentino & Jeffrey B. Harris, Section 1274—The Application of the OID Provisions to Debt Instruments Issued for Property, 9 REV. OF TAX'N OF INDIVIDUALS 315 (1985)