On March 7, 2012, the IRS released Notice 2012-20 (the “Notice”), which:
- clarifies the definition of a “registered” debt obligation;
- provides that the portfolio interest exemption is applicable to “foreign-targeted registered obligations” issued after March 18, 2012 and before January 1, 2014;
- clarifies that regulations will be issued for purposes of clarifying the procedures required for issuing foreign-targeted bearer debt without imposition of the excise tax under Code Section 4701; and
- confirms the exemption from information reporting of interest and original issue discount with respect to certain short-term debt obligations will remain available for obligations issued after March 18, 2012.