Prop. Treas. Reg. § 1.863-7 Allocation of income attributable to certain notional principal contracts under section 863(a).

Proposed 2011-09-16 · REG-111283-11 · 76 FR 57684 · Interprets § 863 · Would amend § 1.863-7

Par. 4. Section 1.863-7 is amended by: 1. Revising the third sentence and removing the fourth sentence of paragraph (a)(1). 2. Adding two sentences to the end of paragraph (a)(2). The revision and addition read as follows:

(a) Scope —(1) Introduction. * * * Notional principal contract income is income attributable to a notional principal contract as defined in § 1.446-3(c). * * *

(2) * * * The rules of this section apply to notional principal contracts as defined in § 1.446-3(c) that are entered into on or after the date of publication of a Treasury decision adopting these rules as final regulations in the Federal Register . Section 1.863-7 as contained in 26 CFR part 1 revised April 1, 2011, continues to apply to notional principal contracts entered into before the date of publication of a Treasury decision adopting these rules as final regulations in the Federal Register .

* * * * *