For Tax Professionals  
FI-32-95 June 20, 1996

Mark to Market for Dealers in Securities; Equity Interests In
Related Parties & the Dealer-Customer Relationship

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [FI-32-95] RIN 1545-AT94

TITLE: Mark to Market for Dealers in Securities; Equity Interests in Related Parties and the Dealer-Customer Relationship

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing.

SUMMARY: This document contains proposed regulations that make mark-to-market accounting inapplicable to most equity interests in related entities. The regulations also relate to the definition of a dealer in securities for certain federal income tax purposes. To qualify as a dealer in securities, a taxpayer must engage in transactions with customers. The proposed regulations concern the existence of dealer-customer relationships. The Revenue Reconciliation Act of 1993 amended the applicable tax law. These regulations provide guidance for taxpayers that engage in securities transactions. This document also provides notice of a public hearing on these proposed regulations.

DATES: Written comments and outlines of oral comments to be presented at a public hearing scheduled for October 15, 1996, at 10 a.m., must be received by September 18, 1996.

ADDRESSES: Send submissions to: CC: DOM: CORP: R (FI-32-95), room 5228, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. In the alternative, submissions may be hand delivered between the hours of 8 a.m. and 5 p.m. to: CC: DOM: CORP: R (FI-32-95), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue NW., Washington, DC 20224. The public hearing will be held in the Commissioner's Conference Room, room 3313, Internal Revenue Building, 1111 Constitution Avenue NW., Washington, DC 20224.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Jo Lynn L. Ricks, (202) 622-3920, or Robert B. Williams, (202) 622-3960; concerning submissions and the hearing, Michael Slaughter, (202) 622-7190 (not toll-free numbers).

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