Internal Revenue Service November 6, 2013 – Federal Register Recent Federal Regulation Documents

This document contains final regulations relating to the transfer or assignment of certain derivative contracts. The final regulations provide guidance to the nonassigning counterparty to a derivative contract and an assignee on certain notional principal contracts that are derivative contracts. The final regulations provide that the nonassigning counterparty does not have an exchange for purposes of Sec. 1.1001-1(a) when certain derivative contracts are transferred or assigned and clarify that the embedded loan rules of Sec. 1.446-3(g)(4) do not apply to such transactions.