General Rules Regarding Inclusion (I.R.C. 451)

September 29, 2018

September 28, 2018: Note that Notice 2018-80 announces the Treasury Department’s intent to not require current inclusion of market discount under I.R.C. 451(b). Market discount under I.R.C. 1276 is usually deferred until the bond is sold. Questions had arisen regarding the impact on this rule by the new provisions of 451 introduced as part of the TCJA.