Qualified Reopening

An issuer that conducts a reopening of its debt securities, offering and selling additional debt securities that have the same terms and conditions as those of an outstanding series, generally will want those additional securities to be treated as fungible with the original securities. For tax purposes, in order for the original and the additional securities to be fungible, the terms of the securities must be identical and either take place within a set time period or meet certain tax tests to be considered a “qualified reopening.” See also “Reopening.”