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Code of Federal Regulations (Last Updated: July 5, 2024) |
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Title 26 - Internal Revenue |
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Chapter I - Internal Revenue Service, Department of the Treasury |
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SubChapter A - Income Tax |
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Part 1 - Income Taxes |
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Nonresident Alien Individuals |
§ 1.871-16T - Specified notional principal contracts (temporary).
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(a) [Reserved]
(b) Specified notional principal contracts between March 18, 2012 and January 1, 2014. With respect to payments made after March 18, 2012 and before January 1, 2014, the term specified notional principal contract means any notional principal contract (as defined in §1.446-3) if—
(1) In connection with entering into such contract, any long party to the contract transfers the underlying security to any short party to the contract;
(2) In connection with the termination of such contract, any short party to the contract transfers the underlying security to any long party to the contract;
(3) The underlying security is not readily tradable on an established securities market; or
(4) In connection with entering into such contract, the underlying security is posted as collateral by any short party to the contract with any long party to the contract.
(c) through (f) [Reserved]
(g) Effective/applicability date. This section applies to payments made on or after January 23, 2012.
(h) Expiration date. This section expires January 16, 2015.
[T.D. 9572, 77 FR 3109, Jan. 23, 2012, as amended by 77 FR 53141, Aug. 31, 2012]