Rev. Rul. 85-163

Rev. Rul. 84-152, 1984-2 C.B. 381, and Rev. Rul. 84-153, 1984-2 C.B. 383, deal with the taxation of interest payments made by United States corporations to Netherlands Antilles corporations.

Pursuant to the authority contained in section 7805(b) of the Internal Revenue Code, the holdings of Rev. Rul. 84-152 and Rev. Rul. 84-153 will not be applied to interest payments made in connection with debt obligations issued prior to October 15, 1984, the date that Rev. Rul. 84-152 and Rev. Rul. 84-153 were published in the Internal Revenue Bulletin and to interest payments made in connection with debt obligations issued on or after October 15, 1984, pursuant to a binding written agreement entered into prior to October 15, 1984, including debt obligations issued on the exercise of a warrant or the conversion of a convertible obligation if such warrant or convertible obligation was issued prior to October 15, 1984.

EFFECT ON OTHER REVENUE RULINGS

Rev. Rul. 85-152 and Rev. Rul. 84-153 are modified.

1. Also released as News Release IR-85-98, dated September 30, 1985.