Understanding De Minimis Amount [Internal Revenue]: A Comprehensive Guide
Definition & Meaning
The term De Minimis Amount refers to a small amount of original issue discount or premium on a financial obligation that is considered negligible for tax purposes. Specifically, it is defined as:
- For original issue discount: An amount that does not exceed two percent of the stated redemption price at maturity, plus any original issue premium that is solely due to reasonable underwriters' compensation.
- For market discount: An amount that does not exceed two percent of the stated redemption price at maturity.
Legal Use & context
The De Minimis Amount is primarily used in tax law, particularly regarding the treatment of original issue discounts and market discounts on bonds and other financial instruments. This term is relevant for taxpayers who need to determine whether a discount or premium is significant enough to affect their tax obligations. Users can manage related forms and procedures through platforms like US Legal Forms, which offer templates for tax-related documents.
Real-world examples
Here are a couple of examples of abatement:
Example 1: A bond has a stated redemption price of $1,000. The De Minimis Amount would be $20 (2% of $1,000). If the original issue discount is $15, it falls under the De Minimis Amount and is not subject to tax.
Example 2: A bond with a market discount of $25, with the same stated redemption price, also qualifies as a De Minimis Amount since it does not exceed $20 (hypothetical example).
Relevant laws & statutes
The De Minimis Amount is defined under 26 CFR 1.148-1(b), which outlines the tax implications of original issue discounts and market discounts.