federal_register: 2015-22554

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
2015-22554 Integrated Hedging Transactions of Qualifying Debt Rule This document contains final regulations that address certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions. The regulations provide that if a taxpayer has identified multiple hedges as being part of a qualified hedging transaction, and the taxpayer has terminated at least one but less than all of the hedges (including a portion of one or more of the hedges), the taxpayer must treat the remaining hedges as having been sold for fair market value on the date of disposition of the terminated hedge. 2015-09-08 2015 9 https://www.federalregister.gov/documents/2015/09/08/2015-22554/integrated-hedging-transactions-of-qualifying-debt https://www.govinfo.gov/content/pkg/FR-2015-09-08/pdf/2015-22554.pdf Treasury Department; Internal Revenue Service 497,254 This document contains final regulations that address certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions. The regulations provide that if a taxpayer has identified...  

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