JS-594: Treasury and IRS Issue Guidance on Forward Contract/Note Units



	FROM THE OFFICE OF PUBLIC AFFAIRS To view or print the Microsoft Word content on this page, download the free Microsoft Word Viewer. July 23, 2003 JS-594 Treasury and IRS Issue Guidance on Forward Contract/Note Units Today the Treasury Department and the Internal Revenue Service issued guidance in the form of a Revenue Ruling regarding a financial product consisting of a forward contract and note that is issued as a single unit. The guidance addresses the question of whether the interest on the note is deductible for tax purposes. The Revenue Ruling clarifies that interest is deductible, but only under specified circumstances. The Revenue Ruling also requests comments whether regulations should be issued under 163(l) to address the policy issues raised by this product. Related Documents: The text of Revenue Ruling 2003-97