Overview
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IRS Releases Final Rules on Integrated Hedging Transactions of Qualifying Debt: Today the IRS released final regulations that address certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions. The final regulations were adopted without substantive change from previously released temporary regulations. 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. While the regulations are effective as of the date of publication in the Federal Register, the regulations apply to leg-outs within the meaning of §1.988-5(a)(6)(ii) that occur on or after September 6, 2012. |