Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2026 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
The Original Issue Discount rules often result in the recognition of income without associated cash, typically an unwelcome tax situation. The OID rules override a taxpayer's normal method of accounting, requiring interest to be allocated over the life of a loan, regardless of when it is actually paid. In this course, participants will learn how to tell if a debt instrument has original issue discount, as well as the rules for allocating OID to different accrual periods. It will also explain how the OID rules apply to sales of property in exchange for a note, in which part of the purchase price may be reclassified as interest, converting what would be capital gain to the seller to ordinary income. Finally, Ms. Kowal will cover the below market loan rules, which impute interest on below market loans between related parties.
Publication Date: July 2023
Designed For
Tax practitioners at all levels who provide advice and return preparation involving debt instruments.
Topics Covered
- Original Issue Discount Rules explanation
- Exceptions to OID rules
- Mechanics of allocating interest to various periods
- Application of OID and imputed interest to debt instruments issued in exchange for property
- Imputing interest under below market loan rules
Learning Objectives
- Identify what original issue discount is, when it applies and when it does not
- Recognize how to calculate how to spread OID across multiple accrual periods
- Describe how OID rules work when debt instruments are issued in exchange for property
- Recognize how to gain familiarity with below market loan rules and interest imputation
Level
Intermediate
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
Basic familiarity with debt instruments.
Advance Preparation
None
Instructor
Jennifer Kowal
Jennifer Kowal, JD, has been a tax professor and the director of the graduate tax program at Loyola Law School in Los Angeles since 2003. Loyola’s graduate tax program offers an LL.M. in Taxation for attorneys and a Master in Tax Law for non-lawyers. Professor Kowal teaches courses in advanced income taxation, income tax timing issues, corporate taxation, and tax research, among others. Prior to teaching at Loyola, Professor Kowal taught in the International Tax Program at Harvard Law School.
She also practiced law with the firms of Irell & Manella in Los Angeles and Ropes & Gray in Boston, advising clients on the taxation of various business transactions, including cross-border, partnership and corporate structures. Professor Kowal holds a BS in Accounting with distinction from the University of Kansas, and a JD from UCLA School of Law, where she was a member of the Order of the Coif.