04 May 2018 Forthcoming regulations will expand exception to definition of US property under Section 956 The IRS has announced (Notice 2018-46) that it plans to issue regulations expanding the exception to the definition of US property under Section 956. In response to taxpayer comments, the exception will apply to an obligation of a United States person, provided the obligation does not exceed the fair market value of cash and readily marketable securities that a US or foreign securities dealer posts or receives as margin or collateral for the obligation in the ordinary course of its business. Additionally, the exception will apply regardless of whether the obligation is connected to a notional principal contract or another derivative. A Tax Alert on the notice is forthcoming. Document ID: 2018-9009 |
