Home      Login


Practice Update: IRS Expands the Safe-Harbor for Swap Assignments to Accommodate Dodd-Frank Implementation  


Author:  Mark H.  Leeds.


Source: Volume 29, Number 01, Fall 2011 , pp.47-50(4)




Journal of Taxation of Investments

< previous article |next article > |return to table of contents

Abstract: 

A new Temporary Treasury Regulation, issued in late July 2011, significantly expands the safe-harbor rules that apply to prevent gain or loss recognition for nonassigning parties to overthecounter derivatives when a dealer counterparty assigns its position to another dealer. The temporary regulation addresses four areas of concern to parties to notional principal contracts and, now, other derivatives.

Keywords: swaps; assignments; notional principal contracts; gain recognition; derivatives

Affiliations:  1: Greenberg Traurig.

Subscribers click here to open full text in PDF.
Non-subscribers click here to purchase this article. $20

< previous article |next article > |return to table of contents