Rev. Rul. 68-614

The taxpayer acquired bonds of a foreign obligor in a transaction that was subject to the Interest Equalization Tax imposed by section 4911 of the Internal Revenue Code of 1954. The period remaining from the date of acquisition by the taxpayer to the stated maturity date of the bonds is ten years but the bonds are callable at any time within the preceding five years.

Held, for the purposes of computing the amount of the Interest Equalization Tax imposed by section 4911 of the Code on the aquisition in the instant case, the period remaining to maturity, as defined in section 4920(a)(7) of the Code, is ten years. The fact that the bonds may be called and repaid before their stated maturity date has no relevancy in determining the period remaining to maturity for the purpose of determining the applicable rate of Interest Equalization Tax. r