IRS guidance Proposed Regs. 1.246-5 and 1.1092(d)-2 Proposed Regs. 1.246-5 and 1.1092(d)-2, REG FI-22-92, 58 F.R. 30727 (May 27, 1993) (excerpt, 1993-1 C.B. 771)

1993-05-27 · Internal Revenue Service

Notice of proposed rulemaking, Dividends Received Deduction, Holding Period Reduced for Periods Where Risk of Loss Diminished. Proposes the reasonably-expected-to-approximate test for substantially similar or related property, options on similar property or an index (worked only for purchased puts), and stock index futures examples. No written-call rule and no 70 percent overlap test.

Cites § 1092 (d)(3)(B)×2 (d)×1