Home      Login

How to Modify the Taxation of Notional Principal Contracts to Eliminate the Whipsaws on Both Sides  

Author:  Edward Dougherty.

Source: Volume 30, Number 03, Spring 2013 , pp.53-76(24)

Journal of Taxation of Investments

next article > |return to table of contents


This article explores the history of taxation of swap contracts, including several iterations of Proposed Regulations, and seeks to provide an alternative regime which provides better certainty for taxpayers that trade in swaps while eliminating both the potential for whipsaw treatment by the IRS and character electivity by taxpayers.

Keywords: swap, notional principal contract, periodic payment, mark to market, realization of income

Affiliations:  1: Deloitte Tax LLP.

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

next article > |return to table of contents