Rev. Rul. 68-585

The taxpayer, a United States person as defined in section 4920(a)(4) of the Internal Revenue Code of 1954, made a personal loan to a resident and citizen of country X in 1967. The loan was evidenced by an interest bearing note payable eighteen months from the date of the note.

Held, the acquisition by the taxpayer of the debt obligation is subject to the interest equalization tax imposed by section 4911(a) of the Code unless the transaction is exempt or excluded from such tax by another provision of the Code.