This revenue procedure provides for an
election that will facilitate the consolidation of two or more
outstanding debt instruments into a single debt instrument. Under
the election, taxpayers can treat certain exchanges of debt
instruments as realization events for federal income tax purposes
even though the exchanges do not result in significant
modifications under Sec. 1.1001-33 of the Income Tax
Regulations.
US Code:
26
USC 1001 Name of Law: Determination of amount of and
recognition of gain or loss
US Code: 26
USC 1012 Name of Law: Basis of property - cost
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.