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TITLE 26 - INTERNAL REVENUE
CHAPTER I - INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY
SUBCHAPTER A - INCOME TAX
PART 1 - INCOME TAXES
1.1256(e) - 1 - Identification of hedging transactions.
(a) Identification and recordkeeping requirements. Under section 1256(e)(2), a taxpayer that enters into a hedging transaction must identify the transaction as a hedging transaction before the close of the day on which the taxpayer enters into the transaction.
(b) Requirements for identification. The identification of a hedging transaction for purposes of section 1256(e)(2) must satisfy the requirements of 1.12212(f)(1). Solely for purposes of section 1256(f)(1), however, an identification that does not satisfy all of the requirements of 1.12212(f)(1) is nevertheless treated as an identification under section 1256(e)(2).
(c) Consistency with 1.12212. Any identification for purposes of 1.12212(f)(1) is also an identification for purposes of this section. If a taxpayer satisfies the requirements of 1.12212(g)(1)(ii), the transaction is treated as if it were not identified as a hedging transaction for purposes of section 1256(e)(2).
(d) Effective date. The rules of this section apply to transactions entered into on or after March 20, 2002.
[T.D. 8985, 67 FR 12870, Mar. 20, 2002; 67 FR 31955, May 13, 2002]
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