When is a derivative treated as debt for US federal income tax purposes?

Journal
Reardon, J.D.
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2001 (Volume 3), No. 2
PriceUSD 45

Two announcements by the IRS with respect to derivative contracts that should be treated like debt for federal income tax purposes, and certain anti-abuse provisions applicable to derivatives and other financial instruments, are discussed.