Recent temporary and proposed regulations change the tax treatment of nonperiodic payments made on swaps, generally treating the payments as a loan and on-market swap.
A KPMG report discusses the general rule and two important exceptions to the rule—the short-term and the full-margin exceptions—and explains what the new rules might mean for U.S. and foreign taxpayers.
Read a June 2015 report [PDF 165 KB] prepared by KPMG LLP: What’s News in Tax: Nonperiodic Payments on Swaps Are Loans (with Two Important Exceptions)
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