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Assignments of derivative contracts

IRS Final Regulations clarify treatment of payments made when notional principal contract is assigned

IRS Final Regulations clarify treatment of payments made when notional principal contract is assigned

In T.D. 9639, 11/05/2013; Reg. § 1.1001-4, IRS has issued final regs on assignments of certain derivative contracts.  The regs clarify that “termination payments” made with respect to assignments that are covered by the regs are not subject to the “embedded loan” rules. Background. Code Sec. 1001 provides rules for the computation and recognition of […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney