Finanse publiczne · 11/05/2012

Modifications to Definition of United States Property

In the Rules and Regulations section of this Federal Register, the IRS and the Treasury Department are issuing temporary regulations relating to the treatment of upfront payments made pursuant to certain notional principal contracts. The temporary regulations provide that certain obligations of United States persons arising from upfront payments made by controlled foreign corporations pursuant to contracts that are cleared by a derivatives clearing organization or clearing agency do not constitute United States property. The text of the temporary regulations also serves as the text of these proposed regulations.