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Foreign Targeted Debt in Bearer Form


A bearer obligation is foreign targeted if:

  • There are arrangements to ensure that the obligation will be sold, or resold in connection with the original issue, only to a person who is not a U.S. person,
  • Interest on the obligation is payable only outside the United States and its possessions, and
  • The face of the obligation contains a statement that any U.S. person who holds the obligation will be subject to limits under the U.S. income tax laws.


Citation: IRC § 1.1275-3 – OID information reporting requirements.