26 CFR §1.956-2T
Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov ↗
- (a)
- (b)
- (1)introductory text through (b)(1)(x) [Reserved] For further guidance, see § 1.956-2(a) through (b)(1)(x).
- (xi)An obligation of a United States person arising from a nonperiodic payment by a controlled foreign corporation (within the meaning of section 957(a)) with respect to a notional principal contract described in § 1.446-3T(g)(4)(ii)(B)(1) or (2) if the following conditions are satisfied—
- (A)The controlled foreign corporation that makes the nonperiodic payment is either a dealer in securities (within the meaning of section 475(c)(1)) or a dealer in commodities; and
- (B)The conditions set forth in § 1.446-3T(g)(4)(ii)(C)(1) (relating to full margin or collateral in cash) are satisfied.
- (C)Examples. The following examples illustrate the application of this paragraph (b)(1)(xi):
- (xi)An obligation of a United States person arising from a nonperiodic payment by a controlled foreign corporation (within the meaning of section 957(a)) with respect to a notional principal contract described in § 1.446-3T(g)(4)(ii)(B)(1) or (2) if the following conditions are satisfied—
- (2)through (c)(4) [Reserved] For further guidance, see § 1.956-2(b)(2) through (c)(4).
- (5)[Reserved]
- (1)introductory text through (b)(1)(x) [Reserved] For further guidance, see § 1.956-2(a) through (b)(1)(x).
- (d)introductory text through (d)(1) [Reserved] For further guidance, see § 1.956-2(b)(2) through (d)(1).
- (2)[Reserved]
- (e)[Reserved] For further guidance see § 1.956-2(e).
- (f)Effective/applicability date. Paragraph (b)(1)(xi) of this section applies to payments described in § 1.956-2T(b)(1)(xi) made on or after May 8, 2015. Taxpayers may apply the rules of paragraph (b)(1)(xi) to payments made before May 8, 2015.
- (g)Expiration date. The applicability of paragraph (b)(1)(xi) of this section expires on May 7, 2018.
- (h)[Reserved]