Finanse publiczne · 08/05/2015

Final and Temporary Regulations on Notional Principal Contracts with Nonperiodic Payments

The US government has released final and temporary regulations that require notional principal contracts with nonperiodic payments to be treated as two separate transactions, involving loans and level payment swaps, subject to certain exceptions. These regulations affect parties involved in notional principal contracts, including US shareholders of controlled foreign corporations and tax-exempt organizations.