offsetting notional principal contract
Defined in 1 place of the United States Code.
The term “offsetting notional principal contract” means, with respect to any property, an agreement which includes—
(A) a requirement to pay (or provide credit for) all or substantially all of the investment yield (including appreciation) on such property for a specified period, and
(B) a right to be reimbursed for (or receive credit for) all or substantially all of any decline in the value of such property.
Source
- 1997–present26 U.S.C. § 1259Internal Revenue Code · Constructive sales treatment for appreciated financial positions · for purposes of this section