Today, Treasury and the IRS issued amended temporary regulations (T.D. 9719) under section 446 relating to guidance for the treatment of nonperiodic payments made or received pursuant to certain notional principal contracts. The amendments delay the applicability of the embedded loan rule for the treatment of nonperiodic payments from November 4, 2015, to the later of January 1, 2017, or six months after the date the final regulations are published. Under the temporary regulations, the embedded loan rule provides that, subject to certain exceptions, a notional principal contract with one or more nonperiodic payments will be treated as two separate transactions consisting of an on-market, level payment swap and one or more loans.
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Treasury, IRS postpone applicability date of embedded loan rule
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