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SEC Filings

RENAISSANCE MEDIA GROUP LLC filed this Form S-4/A on 08/06/1998
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premium." The amount of OID that such Holder must include in its gross income
with respect to such Note for any taxable year is generally reduced by the
portion of such acquisition premium properly allocable to such year. The
information reported by the Obligors to the record Holders of the Notes on an
annual basis will not account for an offset against OID for any portion of the
acquisition premium. Accordingly, each United States Holder should consult its
own tax advisor as to the determination of the acquisition premium amount and
the resulting adjustments to the amount of reportable OID.
  Amortizable Bond Premium. A United States Holder that purchases a Note for
an amount in excess of its principal amount will be considered to have
purchased the Note at a premium and may elect to amortize such premium, using
a constant yield method, over the remaining term of the Note (or, if a smaller
amortization allowance would result, by computing such allowance with
reference to the amount payable on an earlier call date and amortizing such
allowance over the shorter period to such call date). The amount amortized in
any year will be treated as a reduction of the United States Holder's interest
income from the Note. Bond premium on a Note held by a United States Holder
that does not make such an election will decrease the gain or increase the
loss otherwise recognized on disposition of the Note. The election to amortize
bond premium on a constant yield method, once made, applies to all debt
obligations held or subsequently acquired by the electing United States Holder
on or after the first day of the first taxable year to which the election
applies and may not be revoked without the consent of the Internal Revenue
Service (the "Service").
  Market Discount. If a United States Holder purchases, subsequent to its
original issuance, a Note for an amount that is less than its "revised issue
price" as of the purchase date, the amount of the difference generally will be
treated as "market discount," unless such difference is less than a specified
de minimis amount. The Code provides that the revised issue price of a Note
equals its issue price plus the amount of OID includable in the income of all
holders for periods prior to the purchase date (disregarding any deduction for
acquisition premium) reduced by the amount of all prior cash payments on the
Note. Subject to a de minimis exception, a United States Holder will be
required to treat any gain recognized on the sale, exchange, redemption,
retirement or other disposition of the Note as ordinary income to the extent
of the accrued market discount that has not previously been included in
income. In addition, the United States Holder may be required to defer, until
the maturity date of the Note or its earlier disposition in a taxable
transaction, the deduction of all or a portion of the interest expense on any
indebtedness incurred or continued to purchase or carry such Note.
  Any market discount will be considered to accrue ratably during the period
from the date of acquisition to the maturity date of the Note, unless the
United States Holder elects to accrue market discount on a constant interest
method. A United States Holder of a Note may elect to include market discount
in income currently as it accrues (under either the ratable or constant
interest method). This election to include currently, once made, applies to
all market discount obligations acquired in or after the first taxable year to
which the election applies and may not be revoked without the consent of the
Service. If the United States Holder of a Note makes such an election, the
foregoing rules with respect to the recognition of ordinary income on sales
and other dispositions of such instruments, and with respect to the deferral
of interest deductions on debt incurred or maintained to purchase or carry
such debt instruments, would not apply.
  Election to Treat All Interest as OID. A United States Holder of a Note may
elect, subject to certain limitations, to include all interest that accrues on
a Note in gross income on a constant yield basis. For purposes of this
election, interest includes stated interest, OID, market discount, de minimus
OID, de minimis market discount and unstated interest, as adjusted by any
amortizable bond premium or acquisition premium. Special rules and limitations
apply to taxpayers, who make this election; therefore, United States Holders
should consult their tax advisors as to whether they should make this
  Sale, Exchange or Redemption of the Notes. Generally, a sale, exchange or
redemption of the Notes will result in taxable gain or loss equal to the
difference between the amount of cash or other property received and the
United States Holder's adjusted tax basis in the Note. A United States
Holder's adjusted tax basis for determining gain or loss on the sale or other
disposition of a Note will initially equal the cost of the Note to such