offsetting notional principal contract
(2) Offsetting notional principal contract 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.
26 USC § 1259(d)(2)
None identified. Default scope is assumed to be the entire title.