For Tax Professionals  
T.D. 8653 May 16, 1996

Hedging Transactions by Members of a Consolidated Group

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 602 [TD 8653] RIN 1545-AS75

TITLE: Hedging Transactions by Members of a Consolidated Group

AGENCY: Internal Revenue Service, Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations relating to the character and timing of gain or loss from certain hedging transactions entered into by members of a consolidated group. These regulations apply when one member of the group hedges its own risk, hedges the risk of another member, or enters into a risk-shifting transaction with another member. The regulations are needed to provide appropriate rules for these transactions. The regulations provide guidance for corporations that are members of consolidated groups.

DATES: These regulations are effective February 7, 1996. For dates of applicability of these regulations, see 1.446- 4(e)(9)(iv) and 1.1221-2(g)(4), (5), and (6).

FOR FURTHER INFORMATION CONTACT: Jo Lynn Ricks of the Office of the Assistant Chief Counsel (Financial Institutions and Products), telephone (202) 622-3920 (not a toll-free number).

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