The Resource Off-market payments on cleared swaps characterized as "loans" : temporary section 956 regulations establish dealer safe harbor

Off-market payments on cleared swaps characterized as "loans" : temporary section 956 regulations establish dealer safe harbor

Label
Off-market payments on cleared swaps characterized as "loans" : temporary section 956 regulations establish dealer safe harbor
Title
Off-market payments on cleared swaps characterized as "loans" : temporary section 956 regulations establish dealer safe harbor
Creator
Subject
Language
  • eng
  • eng
Summary
Before discussing the Temporary Regulations, this article sets out a brief overview of Code Sec. 956 and the general treatment of investments in United States Property under Code Sec. 951. It then describes the potential classification of upfront swap payments as loans for federal income tax purposes under the notional principal contract regulations
Citation source
In: International tax journal. - Chicago. - Vol. 38 (2012),
http://library.link/vocab/creatorName
Pomierski, W.R
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • swap
  • loan
  • income classification
  • safe harbour
Label
Off-market payments on cleared swaps characterized as "loans" : temporary section 956 regulations establish dealer safe harbor
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2012/G-I/ITJ/4_33-38.zip
Instantiates
Publication
Note
20121015
Label
Off-market payments on cleared swaps characterized as "loans" : temporary section 956 regulations establish dealer safe harbor
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2012/G-I/ITJ/4_33-38.zip
Publication
Note
20121015

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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