The following calculates the de minimis original issue discount ("OID") threshold for a typical loan or note that is required to pay regular cash interest at a single customary rate and fixed (or no) amortization on a quarterly basis. Depending on your specific situation, a result other than as calculated below may be appropriate. An incremental loan or tack-on note that is issued with less than de minimis OID and that has the same terms as the existing debt is generally considered tax fungible with the outstanding debt.
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