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JS-594Today 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.
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