WASHINGTON - The Internal Revenue Service issued a revenue procedure Friday that, effective today, requires taxpayers entering into swaps or other notional principal contracts to notify the IRS if they are changing their accounting methods to comply with recently issued swaps rules.
Revenue Procedure 93-48 requires the taxpayers to file Form 3115 with their tax returns. The returns typically would be submitted to the IRS on March 15 or, if an extension is obtained, on Sept. 15, agency officials said.
The IRS issued the so-called swaps rules, or notional principal contract rules, in October. The rules and the new revenue procedure apply to taxpayers that enter into swap and other notional principal contracts after Dec. 12.
The swaps rules require taxpayers to take nonperiodic payments into account for tax purposes over the term of their contracts. The rules require periodic payments to be taken into account only over the period to which they relate.
The swaps payments could be treated as ordinary or capital gains or losses under the recently-issued hedging rules and other tax regulations, IRS officials said.