Sec. 105. Swap payments made from the United States to persons offshore
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Section 871(a)(1) is amended— by inserting swap payments (as identified in section 1256(b)(2)(B)), after annuities, in subparagraph (A), and by adding at the end the following new sentence: In the case of swap payments, the source of a swap payment is determined by reference to the location of the payor. . Section 881(a) is amended— by inserting swap payments (as identified in section 1256(b)(2)(B)), after annuities, in paragraph (1), and by adding at the end the following new sentence: In the case of swap payments, the source of a swap payment is determined by reference to the location of the payor. .