26 C.F.R. § 1.1001-4 Modifications of certain notional principal contracts.
Title 26 - Internal Revenue
(a) Dealer assignments. For purposes of §1.1001–1(a), the substitution of a new party on an interest rate or commodity swap, or other notional principal contract (as defined in §1.446–3(c)(1)), is not treated as a deemed exchange by the nonassigning party of the original contract for a modified contract that differs materially either in kind or in extent if— (1) The party assigning its rights and obligations under the contract and the party to which the rights and obligations are assigned are both dealers in notional principal contracts, as defined in §1.446–3(c)(4)(iii); and (2) The terms of the contract permit the substitution. (b) Effective date. This section applies to assignments of interest rate swaps, commodity swaps, and other notional principal contracts occurring on or after September 23, 1996. [T.D. 8763, 63 FR 4396, Jan. 29, 1998]
Title 26: Internal Revenue
PART 1—INCOME TAXES
Determination of Amount of and Recognition of Gain or Loss
§ 1.1001-4 Modifications of certain notional principal contracts.
