Internal Revenue Service
Revenue Ruling
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smRev. Rul. 64-63
1964-1 C.B. 302
Sec. 1031
Sec. 1037
IRS Headnote
Under section 1037(a) of the Internal Revenue Code of 1954, no gain or loss will be recognized upon the exchange of the 3 3/4 percent Treasury Notes of Series E-1964; 5 percent Treasury Notes of Series B-1964; 3 3/4 percent Treasury Notes of Series F-1964; 4 7/8 percent Treasury Notes of Series C-1964; 2 5/8 percent Treasury Bonds of 1965; 4 5/8 percent Treasury Notes of Series A-1965, as offered by Treasury Department Circulars, Public Debt Series Nos. 1-64, and 2-64, dated January 9, 1964.
Full Text
Rev. Rul. 64-63
In the Treasury Department Circulars listed below, the Secretary of the Treasury offered the Treasury Bonds specified in exchange for other Treasury securities as follows:
Treasury Department Circular, Public Debt Series No. 1-64, dated
January 9, 1964, 29 F.R. 357
Bonds offered Exchanges accepted
4 percent Treasury Bonds of 1970 3 3/4 percent Treasury Notes of
99.05 percent of their face Series E-1964, dated August 1,
value. 1961, due August 15, 1964.
4 percent Treasury Bonds of 1970 5 percent Treasury Notes of Series
at 98.35 percent of their face B-1964, dated October 15, 1959,
value. due August 15, 1964.
4 percent Treasury Bonds at 1970 3 3/4 percent Treasury Notes of
at 99.05 percent of their face Series F-1964, dated August 15,
value. 1963, due November 15, 1964.
4 percent Treasury Bonds of 1970 4 7/8 percent Treasury Notes of
at 98.15 percent of their face Series C-1964, dated February 15,
value. 1960, due November 15, 1964.
4 percent Treasury Bonds of 1970 2 5/8 percent Treasury Bonds of
at 100.25 percent of their face 1965 dated June 15, 1958, due
value. February 15, 1965.
4 percent Treasury Bonds of 1970 4 5/8 percent Treasury Notes of
at 98.20 percent of their face Series A-1965, dated May 15, 1960,
value. due May 15, 1965.
Treasury Department Circular, Public Debt Series No. 2-64, dated
January 9, 1964, 29 F.R. 358
Bonds offered Exchanges accepted
4 1/4 percent Treasury Bonds of 3 3/4 percent Treasury Notes of
1975-85 at 99.95 percent of Series E-1964, dated August 1,
their face value. 1961, due August 15, 1964.
4 1/4 percent Treasury Bonds of 5 percent Treasury Notes of
1975-85 at 99.25 percent of Series B-1964, dated October 15,
their face value. 1959, due August 15, 1964.
4 1/4 percent Treasury Bonds of 3 3/4 percent Treasury Notes of
1975-85 at 99.95 percent of Series F-1964, dated August 15,
their face value. 1963, due November 15, 1964.
4 1/4 percent Treasury Bonds of 4 7/8 percent Treasury Notes of
1975-85 at 99.05 percent of Series C-1964, dated February 15,
their face value. 1960, due November 15, 1964.
4 1/4 percent Treasury Bonds of 2 5/8 percent Treasury Bonds of
1975-85 at 101.15 percent of 1965, dated June 15, 1958, due
their face value. February 15, 1965.
4 1/4 percent Treasury Bonds of 4 5/8 percent Treasury Notes of
1975-85 at 99.10 percent of Series A-1965, dated May 15, 1960
their face value. due May 15, 1965.
The income derived from the bonds issued in exchange is subject to all taxes imposed under the Internal Revenue Code of 1954. The bonds are subject to estate, inheritance, gift or other excise taxes, whether Federal or State, but are exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by any local taxing authority.
The bonds will be acceptable to secure deposits of public moneys. They will not be acceptable in payment of taxes.
Pursuant to the provisions of section 1037(a) of the Code, the Secretary of the Treasury has declared that no gain or loss shall be recognized, for Federal income tax purposes, upon the exchange with the United States of the eligible securities enumerated herein solely for the 4 percent Treasury Bonds of 1970 and the 4 1/4 percent Treasury Bonds of 1975-85 as offered by the Department Circulars, Public Debt Series Nos. 1-64 and 2-64.
However, section 1031(b) of the Code requires the recognition of any gain realized on the exchange to the extent that money is received by the security holder in connection with the exchange. The payment due to the subscriber on account of the issue price of the bonds to be issued is the maximum amount of gain, if any, recognized at the time of the exchange.
To the extent not recognized at the time of the exchange, gain or loss, if any, upon the obligations surrendered in exchange will be taken into account upon the disposition or redemption of the new obligations.