The following calculates the de minimis original issue discount ("OID") threshold for a typical loan or note that is required to pay regular cash interest at a single customary rate and fixed (or no) amortization on a quarterly basis. Depending on your specific situation, a result other than as calculated below may be appropriate. An incremental loan or tack-on note that is issued with less than de minimis OID and that has the same terms as the existing debt is generally considered tax fungible with the outstanding debt.
OID Threshold Calculator
