- 6 - debt instruments. Petitioner financed approximately 10 percent of its mortgage purchases through the issuance of long-term debt.3 I. Favorable Financing Intangible Assets At the close of business on December 31, 1984, petitioner had outstanding long-term indebtedness on a number of debt instruments. The effective contract interest rates4 on some of these outstanding long-term debt obligations were below the interest rates that petitioner would have incurred on January 1, 1985, had it issued comparable debt instruments in the market for the remaining term of the particular debt instrument. Petitioner’s favorable financing intangible assets consisted of the benefits it derived from financing arrangements that required it to pay interest at rates below those prevailing in the financial markets as of January 1, 1985. As of January 1, 1985, petitioner had the following 30 outstanding long-term debt instruments, which had below-market interest rates and market prices that were lower than the adjusted issue prices. 3 In this context, debt includes collateralized mortgage obligations (CMOs) and guaranteed mortgage certificates (GMCs). 4 The effective contract interest rate is the adjusted coupon interest rate (or for zero-coupon bonds, the adjusted effective interest rate). The adjusted coupon interest rate equals the sum of the coupon rate of interest, the hedging gain or loss percentage, and any discount from the face value when the debt obligation was issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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