Inter-bank lending and borrowing, foreign exchange trading and security sales occur in the global financial markets twenty four hours a day. Financial arrangements include re-packaging new products or hedging with existing products. FPT generally deals with issues that may involve the financing of business and not necessarily with the direct product or service rendered by a business. However, financial products can also be used to manage direct product risk, for example, the hedging of price changes. Generally, issues center around functions handled by the Chief Financial Officer, Treasurer, Comptroller or any other department responsible for worldwide funding, risk management, investing or refinancing in corporations, rather than the tax department.
Issues can be geographic.
For example, there may be many dealer issues in locations with major financial centers and few or no dealer issues in locations where there are no financial markets. In addition, a number of judicial decisions have also impacted FPT tax principals. The FPT program provides an organizational structure that is flexible and allows for the timely identification and dissemination of FPT information in a uniform and consistent manner. FPT accumulates and disseminates, to the field examination techniques, identified issues regarding avoidance and evasion schemes, and other information useful in planning and executing examinations. FPT works closely in conjunction with the Office of Chief Counsel, both Domestic and International and Appeals Division in order to achieve FPT objectives and goals.