BP » Topics » Debt Securities Purchased at a Premium.

This excerpt taken from the BP 424B5 filed Aug 7, 2009.

Debt Securities Purchased at a Premium.

If you purchase your debt security for an amount in excess of its principal amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable

 

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bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also “Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

This excerpt taken from the BP 424B5 filed May 5, 2009.

Debt Securities Purchased at a Premium.

If you purchase your debt security for an amount in excess of its principal amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable

 

34


Table of Contents

bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also “Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

This excerpt taken from the BP F-3ASR filed Mar 13, 2009.

Debt Securities Purchased at a Premium.

If you purchase your debt security for an amount in excess of its principal amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable

 

34


Table of Contents

bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also “Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

These excerpts taken from the BP 424B5 filed Mar 13, 2009.

Debt Securities Purchased at a Premium.

 

If you purchase your debt security for an amount in excess of its principal amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also “Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

Debt Securities Purchased at a Premium.

STYLE="margin-top:0px;margin-bottom:-6px"> 

If you purchase your debt security for an amount in excess of its principal
amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable
bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the
foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets
interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest
on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also
“Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Purchase, Sale and Retirement of the Debt Securities.

SIZE="1"> 

Your tax basis in your debt security will generally be the U.S. dollar cost, as defined below, of your debt security,
adjusted by:

 







  

adding any OID or market discount, de minimis original issue discount and de minimis market discount previously included in income with respect to your debt
security, and then

 







  

subtracting any payments on your debt security that are not qualified stated interest payments and any amortizable bond premium applied to reduce interest on your
debt security.

 

If you purchase your debt security with
foreign currency, the U.S. dollar cost of your debt security will generally be the U.S. dollar value of the purchase price on the date of purchase. However, if you are a cash basis taxpayer, or an accrual basis taxpayer if you so elect, and your
debt security is traded on an established securities market, as defined in the applicable Treasury regulations, the U.S. dollar cost of your debt security will be the U.S. dollar value of the purchase price on the settlement date of your purchase.

 

You will generally recognize gain or loss on the sale or
retirement of your debt security equal to the difference between the amount you realize on the sale or retirement and your tax basis in your debt security. If your debt security is sold or retired for an amount in foreign currency, the amount you
realize will be the U.S. dollar value of such amount on the date the debt security is disposed of or retired, except that in the case of a debt security that is traded on an established securities market, as defined in the applicable Treasury
regulations, a cash basis taxpayer, or an accrual basis taxpayer that so elects, will determine the amount realized based on the U.S. dollar value of the foreign currency on the settlement date of the sale.

STYLE="margin-top:0px;margin-bottom:0px"> 

You will recognize capital gain or loss when you sell or retire your debt
security, except to the extent:

 







  

described above under “—Original Issue Discount—Short-Term Debt Securities” or “—Market Discount”,


 







  

attributable to accrued but unpaid interest,

 







  

the rules governing contingent payment obligations apply, or

SIZE="1"> 







  

attributable to changes in exchange rates as described below.

SIZE="1"> 

 


34







Table of Contents


Capital gain of a noncorporate United States holder that is recognized before January 1, 2011 is generally taxed at a
maximum rate of 15% where the holder has a holding period greater than one year.

 

FACE="Times New Roman" SIZE="2">You must treat any portion of the gain or loss that you recognize on the sale or retirement of a debt security as ordinary income or loss to the extent attributable to changes in exchange rates. However, you take
exchange gain or loss into account only to the extent of the total gain or loss you realize on the transaction.

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Exchange of Amounts in Other Than U.S. Dollars

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">If you receive foreign currency as interest on your debt security or on the sale or retirement of your debt security, your tax basis in the foreign
currency will equal its U.S. dollar value when the interest is received or at the time of the sale or retirement. If you purchase foreign currency, you generally will have a tax basis equal to the U.S. dollar value of the foreign currency on the
date of your purchase. If you sell or dispose of a foreign currency, including if you use it to purchase debt securities or exchange it for U.S. dollars, any gain or loss recognized generally will be ordinary income or loss.

STYLE="margin-top:0px;margin-bottom:0px"> 

These excerpts taken from the BP 424B5 filed Mar 6, 2009.

Debt Securities Purchased at a Premium.

 

If you purchase your debt security for an amount in excess of its principal amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also “Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

Debt Securities Purchased at a Premium.

STYLE="margin-top:0px;margin-bottom:-6px"> 

If you purchase your debt security for an amount in excess of its principal
amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable
bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the
foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets
interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest
on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also
“Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Purchase, Sale and Retirement of the Debt Securities.

SIZE="1"> 

Your tax basis in your debt security will generally be the U.S. dollar cost, as defined below, of your debt security,
adjusted by:

 







  

adding any OID or market discount, de minimis original issue discount and de minimis market discount previously included in income with respect to your debt
security, and then

 







  

subtracting any payments on your debt security that are not qualified stated interest payments and any amortizable bond premium applied to reduce interest on your
debt security.

 

If you purchase your debt security with
foreign currency, the U.S. dollar cost of your debt security will generally be the U.S. dollar value of the purchase price on the date of purchase. However, if you are a cash basis taxpayer, or an accrual basis taxpayer if you so elect, and your
debt security is traded on an established securities market, as defined in the applicable Treasury regulations, the U.S. dollar cost of your debt security will be the U.S. dollar value of the purchase price on the settlement date of your purchase.

 

You will generally recognize gain or loss on the sale or
retirement of your debt security equal to the difference between the amount you realize on the sale or retirement and your tax basis in your debt security. If your debt security is sold or retired for an amount in foreign currency, the amount you
realize will be the U.S. dollar value of such amount on the date the debt security is disposed of or retired, except that in the case of a debt security that is traded on an established securities market, as defined in the applicable Treasury
regulations, a cash basis taxpayer, or an accrual basis taxpayer that so elects, will determine the amount realized based on the U.S. dollar value of the foreign currency on the settlement date of the sale.

STYLE="margin-top:0px;margin-bottom:0px"> 

You will recognize capital gain or loss when you sell or retire your debt
security, except to the extent:

 







  

described above under “—Original Issue Discount—Short-Term Debt Securities” or “—Market Discount”,


 







  

attributable to accrued but unpaid interest,

 







  

the rules governing contingent payment obligations apply, or

SIZE="1"> 







  

attributable to changes in exchange rates as described below.

SIZE="1"> 

 


34







Table of Contents


Capital gain of a noncorporate United States holder that is recognized before January 1, 2011 is generally taxed at a
maximum rate of 15% where the holder has a holding period greater than one year.

 

FACE="Times New Roman" SIZE="2">You must treat any portion of the gain or loss that you recognize on the sale or retirement of a debt security as ordinary income or loss to the extent attributable to changes in exchange rates. However, you take
exchange gain or loss into account only to the extent of the total gain or loss you realize on the transaction.

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Exchange of Amounts in Other Than U.S. Dollars

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">If you receive foreign currency as interest on your debt security or on the sale or retirement of your debt security, your tax basis in the foreign
currency will equal its U.S. dollar value when the interest is received or at the time of the sale or retirement. If you purchase foreign currency, you generally will have a tax basis equal to the U.S. dollar value of the foreign currency on the
date of your purchase. If you sell or dispose of a foreign currency, including if you use it to purchase debt securities or exchange it for U.S. dollars, any gain or loss recognized generally will be ordinary income or loss.

STYLE="margin-top:0px;margin-bottom:0px"> 

These excerpts taken from the BP 424B5 filed Nov 5, 2008.

Debt Securities Purchased at a Premium.

 

If you purchase your debt security for an amount in excess of its principal amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also “Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

Debt Securities Purchased at a Premium.

STYLE="margin-top:0px;margin-bottom:-6px"> 

If you purchase your debt security for an amount in excess of its principal
amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable
bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the
foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets
interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest
on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also
“Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Purchase, Sale and Retirement of the Debt Securities.

SIZE="1"> 

Your tax basis in your debt security will generally be the U.S. dollar cost, as defined below, of your debt security,
adjusted by:

 







  

adding any OID or market discount, de minimis original issue discount and de minimis market discount previously included in income with respect to your debt
security, and then

 







  

subtracting any payments on your debt security that are not qualified stated interest payments and any amortizable bond premium applied to reduce interest on your
debt security.

 

If you purchase your debt security with
foreign currency, the U.S. dollar cost of your debt security will generally be the U.S. dollar value of the purchase price on the date of purchase. However, if you are a cash basis taxpayer, or an accrual basis taxpayer if you so elect, and your
debt security is traded on an established securities market, as defined in the applicable Treasury regulations, the U.S. dollar cost of your debt security will be the U.S. dollar value of the purchase price on the settlement date of your purchase.

 

You will generally recognize gain or loss on the sale or
retirement of your debt security equal to the difference between the amount you realize on the sale or retirement and your tax basis in your debt security. If your debt security is sold or retired for an amount in foreign currency, the amount you
realize will be the U.S. dollar value of such amount on the date the debt security is disposed of or retired, except that in the case of a debt security that is traded on an established securities market, as defined in the applicable Treasury
regulations, a cash basis taxpayer, or an accrual basis taxpayer that so elects, will determine the amount realized based on the U.S. dollar value of the foreign currency on the settlement date of the sale.

STYLE="margin-top:0px;margin-bottom:0px"> 

You will recognize capital gain or loss when you sell or retire your debt
security, except to the extent:

 







  

described above under “—Original Issue Discount—Short-Term Debt Securities” or “—Market Discount”,


 







  

attributable to accrued but unpaid interest,

 







  

the rules governing contingent payment obligations apply, or

SIZE="1"> 







  

attributable to changes in exchange rates as described below.

SIZE="1"> 

 


34







Table of Contents


Capital gain of a noncorporate United States holder that is recognized before January 1, 2011 is generally taxed at a
maximum rate of 15% where the holder has a holding period greater than one year.

 

FACE="Times New Roman" SIZE="2">You must treat any portion of the gain or loss that you recognize on the sale or retirement of a debt security as ordinary income or loss to the extent attributable to changes in exchange rates. However, you take
exchange gain or loss into account only to the extent of the total gain or loss you realize on the transaction.

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Exchange of Amounts in Other Than U.S. Dollars

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">If you receive foreign currency as interest on your debt security or on the sale or retirement of your debt security, your tax basis in the foreign
currency will equal its U.S. dollar value when the interest is received or at the time of the sale or retirement. If you purchase foreign currency, you generally will have a tax basis equal to the U.S. dollar value of the foreign currency on the
date of your purchase. If you sell or dispose of a foreign currency, including if you use it to purchase debt securities or exchange it for U.S. dollars, any gain or loss recognized generally will be ordinary income or loss.

STYLE="margin-top:0px;margin-bottom:0px"> 

These excerpts taken from the BP 424B5 filed Mar 13, 2008.

Debt Securities Purchased at a Premium.

 

If you purchase your debt security for an amount in excess of its principal amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also “Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

Debt Securities Purchased at a Premium.

STYLE="margin-top:0px;margin-bottom:-6px"> 

If you purchase your debt security for an amount in excess of its principal
amount, you may elect to treat the excess as amortizable bond premium. If you make this election, you will reduce the amount required to be included in your income each year with respect to interest on your debt security by the amount of amortizable
bond premium allocable to that year, based on your debt security’s yield to maturity. If your debt security is denominated in, or determined by reference to, a foreign currency, you will compute your amortizable bond premium in units of the
foreign currency and your amortizable bond premium will reduce your interest income in units of the foreign currency. Gain or loss recognized that is attributable to changes in exchange rates between the time your amortized bond premium offsets
interest income and the time of the acquisition of your debt security is generally taxable as ordinary income or loss. If you make an election to amortize bond premium, it will apply to all debt instruments, other than debt instruments the interest
on which is excludible from gross income, that you hold at the beginning of the first taxable year to which the election applies or that you thereafter acquire, and you may not revoke it without the consent of the Internal Revenue Service. See also
“Original Issue Discount—Election to Treat All Interest as Original Issue Discount.”

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Purchase, Sale and Retirement of the Debt Securities.

SIZE="1"> 

Your tax basis in your debt security will generally be the U.S. dollar cost, as defined below, of your debt security,
adjusted by:

 







  

adding any OID or market discount, de minimis original issue discount and de minimis market discount previously included in income with respect to your debt
security, and then

 







  

subtracting any payments on your debt security that are not qualified stated interest payments and any amortizable bond premium applied to reduce interest on your
debt security.

 

If you purchase your debt security with
foreign currency, the U.S. dollar cost of your debt security will generally be the U.S. dollar value of the purchase price on the date of purchase. However, if you are a cash basis taxpayer, or an accrual basis taxpayer if you so elect, and your
debt security is traded on an established securities market, as defined in the applicable Treasury regulations, the U.S. dollar cost of your debt security will be the U.S. dollar value of the purchase price on the settlement date of your purchase.

 

You will generally recognize gain or loss on the sale or
retirement of your debt security equal to the difference between the amount you realize on the sale or retirement and your tax basis in your debt security. If your debt security is sold or retired for an amount in foreign currency, the amount you
realize will be the U.S. dollar value of such amount on the date the debt security is disposed of or retired, except that in the case of a debt security that is traded on an established securities market, as defined in the applicable Treasury
regulations, a cash basis taxpayer, or an accrual basis taxpayer that so elects, will determine the amount realized based on the U.S. dollar value of the foreign currency on the settlement date of the sale.

STYLE="margin-top:0px;margin-bottom:0px"> 

You will recognize capital gain or loss when you sell or retire your debt
security, except to the extent:

 







  

described above under “—Original Issue Discount—Short-Term Debt Securities” or “—Market Discount”,


 







  

attributable to accrued but unpaid interest,

 







  

the rules governing contingent payment obligations apply, or

SIZE="1"> 







  

attributable to changes in exchange rates as described below.

SIZE="1"> 

 


34







Table of Contents


Capital gain of a noncorporate United States holder that is recognized before January 1, 2011 is generally taxed at a
maximum rate of 15% where the holder has a holding period greater than one year.

 

FACE="Times New Roman" SIZE="2">You must treat any portion of the gain or loss that you recognize on the sale or retirement of a debt security as ordinary income or loss to the extent attributable to changes in exchange rates. However, you take
exchange gain or loss into account only to the extent of the total gain or loss you realize on the transaction.

 

STYLE="margin-top:0px;margin-bottom:0px; margin-left:2%">Exchange of Amounts in Other Than U.S. Dollars

 

STYLE="margin-top:0px;margin-bottom:0px; text-indent:4%">If you receive foreign currency as interest on your debt security or on the sale or retirement of your debt security, your tax basis in the foreign
currency will equal its U.S. dollar value when the interest is received or at the time of the sale or retirement. If you purchase foreign currency, you generally will have a tax basis equal to the U.S. dollar value of the foreign currency on the
date of your purchase. If you sell or dispose of a foreign currency, including if you use it to purchase debt securities or exchange it for U.S. dollars, any gain or loss recognized generally will be ordinary income or loss.

STYLE="margin-top:0px;margin-bottom:0px"> 

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