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

Proposed regulation, not in force. REG-119514-15, 82 FR 60135, published 2017-12-19 <https://www.federalregister.gov/documents/2017/12/19/2017-27320/exclusion-of-foreign-currency-gain-or-loss-related-to-business-needs-from-foreign-personal-holding>. Interprets 26 U.S.C. § 446.

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.