Page 127 - Large Business IRS Training Guides

Interest for Purposes of IRC § 163(j)

Interest Equivalents

Examples of other amounts that are closely

related to interest (interest equivalents):

• Premium on debt • Section 1258 Gain

instruments • Commitment fees

• Ordinary income or loss • Debt issuance costs

on certain debt • Guaranteed payments

instruments • Income, deduction, gain or

• Substitute interest loss from a derivative that

payments alters the yield or effective

(Securities Lending) cost of borrowing of the

• Factoring income taxpayer. (Hedging)

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