Home      Login


Replacing a Swap Counterparty  A Primer on Deemed Termination, Withholding, and Other U.S. Tax Issues


Author:  Angela Sellman.


Source: Volume 22, Number 06, July/August 2009 , pp.29-35(7)




Journal of Taxation and Regulation of Financial Institutions

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

Abstract: 

The current financial crisis has prompted an increase in the practice of substituting counterparties to swaps and other derivative contracts. When substituting counterparties to swaps or other derivative contracts—a practice becoming all the more common in the current economic climate—the nonassigning party must consider the multiplicity of related U.S. income tax consequences. This article considers some of the federal income tax consequences to a non-assigning party resulting from the replacement of a counterparty to a swap.

Keywords: 1001-4 Regulation; Derivative Contracts

Affiliations:  1: Freshfields Bruckhaus Deringer US LLP.

Subscribers click here to open full text in PDF.
Non-subscribers click here to purchase this article. $25

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