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26 CFR §1.956-2T

Verified against eCFR.gov as of June 20, 2026View official text on eCFR.gov
  1. (a)
    1. (1)through (a)(3) [Reserved] For further guidance, see § 1.956-2(a) through (b)(1)(x).
    2. (4)[Reserved]
  2. (b)
    1. (1)introductory text through (b)(1)(x) [Reserved] For further guidance, see § 1.956-2(a) through (b)(1)(x).
      1. (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—
        1. (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
        2. (B)The conditions set forth in § 1.446-3T(g)(4)(ii)(C)(1) (relating to full margin or collateral in cash) are satisfied.
        3. (C)Examples. The following examples illustrate the application of this paragraph (b)(1)(xi):
          1. (b)
    2. (2)through (c)(4) [Reserved] For further guidance, see § 1.956-2(b)(2) through (c)(4).
    3. (5)[Reserved]
  3. (d)introductory text through (d)(1) [Reserved] For further guidance, see § 1.956-2(b)(2) through (d)(1).
    1. (2)[Reserved]
  4. (e)[Reserved] For further guidance see § 1.956-2(e).
  5. (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.
  6. (g)Expiration date. The applicability of paragraph (b)(1)(xi) of this section expires on May 7, 2018.
  7. (h)[Reserved]