id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-493	Steinberg, Lewis R.	Selected Issues In The Taxation Of Swaps, Structured Finance and Other Financial Products	2022	44	.pdf	application/pdf	23142	858	52	Thus, as discussed above, the Service does not treat interest rate swap income and expense as interest, even though it is based on prevailing interest rates, and the Service clearly intends to continue to apply the rules of Regulations section 1.863-7, rather than the sourcing rules for interest contained in sections 861(a)(1) and 862(a)(1), to interest rate swap payments. It is true, of course, that the drafters of Regulations section 1.863-7 did not lose much, if any, potential revenue for the fisc by treating interest rate swap payments as foreign source income, since most interest payments on real debt are not subject to withholding tax because of the portfolio interest rules of sections 871(h) and 881(c).	cache/ftr-493.pdf	txt/ftr-493.txt