Private Investment Fund Tax and Accounting Forum


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


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