- 32 - investment of a given sum at the rate of the higher yielding GIC's would substantially exceed amounts earned upon investment of that same sum at the yield rate of the Bonds. The regulations calculate the excess amount to be paid to the United States as the future value of all nonpurpose receipts over the future value of all nonpurpose payments. Sec. 1.148- 2(a)(1) and (2), Income Tax Regs. "Receipts" are defined to include any amount actually or constructively received with respect to the investment (but not reduced by administrative or similar expenses). Sec. 1.148-2(b)(2)(i), Income Tax Regs.15 "Payments" are defined to include the amount of gross proceeds of the bond issue to which the investment is allocated (not including administrative or similar expenses), whether or not the investment was directly purchased with such gross proceeds. Sec. 1.148-2(b)(3)(i) and (ii), Income Tax Regs. The parties have stipulated the schedule of payments for and receipts pursuant to the Whitewater GIC as follows: Date Payment Receipt 2/20/86 $16,110,817.98 5/27/86 $678,125 11/26/86 678,125 5/27/87 678,125 11/25/87 678,125 5/27/88 678,125 11/25/88 678,125 15For an investment held at the end of a computation period, the term "receipt" includes the fair market value of the investment at the end of that period. Sec. 1.148-2(b)(2)(iii), Income Tax Regs.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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