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A debt modification is considered substantial under a quantitative and qualitative assessment as follows. Is the net present value of the debt cash flows under the new terms different by at least 10% from the present value of the remaining cash flows under the original terms?
Adjusted issue price. The adjusted issue price at the beginning of any subsequent accrual period is the sum of the issue price and all the OID includible in income before that accrual period minus any payment previously made on the debt instrument, other than a payment of qualified stated interest.
A change in yield is a docHub debt modifica- tion if the yield varies from the annual yield on the unmodified debt (determined as of the modification date) by more than the greater of (1) one-quarter of 1 percent (25 basis points) or (2) 5 percent of the annual yield of the unmodified debt (0.05 x annual yield).
02 Section 1.1001-3 provides rules to determine whether a modification of the terms of a debt instrument results in an exchange of the original debt instrument for a modified instrument that differs materially either in kind or in extent.
. 02 Section 1.1001-3 provides rules to determine whether a modification of the terms of a debt instrument results in an exchange of the original debt instrument for a modified instrument that differs materially either in kind or in extent.
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To perform the 10% test, the discounted cash flows of the original debt are compared to those of the new debt as of the modification date. Because the change in present value of cash flows is less than 10%, the change is considered a modification.
Adjusted issue price. The adjusted issue price of a debt instrument at the beginning of an accrual period is used to figure the OID allocable to that period. In general, the adjusted issue price at the beginning of the debt instruments first accrual period is its issue price.
A debt modification is considered substantial under a quantitative and qualitative assessment as follows. Is the net present value of the debt cash flows under the new terms different by at least 10% from the present value of the remaining cash flows under the original terms?
Under Treasury Regulation Section 1.1001-3(e)(2), a modification of a debt instrument is a docHub modification if the annual yield of the modified instrument varies by more than the greater of 25 basis points or 5% of the annual yield of the unmodified instrument.
A substantial modification is the last manufacturing process which changes the nature of the packaging component. A substantial modification is a manufacturing process that changes the packaging components features.

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