TD 9157 (Final) Guidance Regarding the Treatment of Certain Contingent Payment Debt Instruments w/ one or more Payments that are Denominated in, or Determined by Reference to, a Nonfunctional Currency

This document contains previously approved final regulations regarding the treatment of contingent payment debt instruments for which one or more payments are denominated in, or determined by reference to, a currency other than the taxpayer’s functional currency. These regulations are necessary because current regulations do not provide guidance concerning the tax treatment of such instruments. The regulations affect issuers and holders of such instruments including investment banks and others who hold these debt instruments for investments.

The latest form for TD 9157 (Final) Guidance Regarding the Treatment of Certain Contingent Payment Debt Instruments w/ one or more Payments that are Denominated in, or Determined by Reference to, a Nonfunctional Currency expires 2022-02-28 and can be found here.