Prop. Treas. Reg. § 1.446-4 Hedging transactions.

Proposed 2017-12-19 · REG-119514-15 · 82 FR 60135 · Interprets § 446 · Would amend § 1.446-4

Par. 2. Section 1.446-4 is amended by: 1. Revising the first sentence of paragraph (a). 2. Revising the heading of paragraph (g) and adding a sentence at the end of paragraph (g). 3. Removing paragraph (h). The revisions and addition read as follows:

(a) In general. Except as provided in this paragraph (a), a hedging transaction as defined in § 1.1221-2(b) (whether or not the character of gain or loss from the transaction is determined under § 1.1221-2) and a bona fide hedging transaction as defined in § 1.954-2(a)(4)(ii) must be accounted for under the rules of this section. * * *

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(g) Applicability date. * * * This section applies to a bona fide hedging transaction (as defined in § 1.954-2(a)(4)(ii)) entered into on or after the date that these regulations are published as final regulations in the Federal Register.