Page 33 - Large Business IRS Training Guides

BEP – QDP
Exception

A QDP is any payment (subject to certain exclusions,
on the following page) made by a
see discussions
to a derivative with respect
taxpayer to a FRP pursuant
to which the taxpayer
–

• Recognizes
gain or loss as if the derivative were sold

for
its fair market value on the last business day of the
time required by the
taxable year (and any additional
method of accounting),
Code or the taxpayer’s

• Treats
any gain or loss so recognized as ordinary, and
the character of all items of income, deduction,
• Treats
gain, or
loss with respect to a payment pursuant to the

derivative as ordinary

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