William R. Pomierski will present "Notional Principal Contracts — Separating Fact from Fiction" at the Private Investment Fund Tax and Accounting Forum.
Topics will include:
- What is the status of the proposed regulations?
- Is there a difference in how trader funds and investor funds are treated?
- Can the wait and see method still be used?
- How are bullet swaps treated under proposed regulations and does it matter?
- How should nonperiodic payments be treated?
- What is a termination payment and how is it distinguished from other payments?
- Impact of 871(m)
- Tax clauses in swap contracts