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Internal Revenue Service › Hedges

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

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What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

ASKramer Law

Taxation of Foreign Currency Transactions Part IV: Hedging & Section 1.988-5(a) Debt Hedges

ASKramer Law on

Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more

ASKramer Law

Hedging: Inadvertent Errors and Tax Identification

ASKramer Law on

Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more

Holland & Knight LLP

IRS Promotes Use of Fallback Language to Assist with Libor, IBOR Transition

Holland & Knight LLP on

The Internal Revenue Service (IRS) released Revenue Procedure 2020-44 to assist the market's transition from the London Interbank Offered Rate (Libor) and other interbank offered rates (IBORs) to alternative reference rates...more

Dechert LLP

New Proposed Tax Regulations on Replacing LIBOR with Other Variable Rates

Dechert LLP on

On October 9, 2019, the U.S. Department of the Treasury and the Internal Revenue Service proposed regulations (“Proposed Regulations”) addressing the transition from London interbank offered rate (“LIBOR”) to the use of...more

Morrison & Foerster LLP

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, and Some Ugly

Morrison & Foerster LLP on

On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid under certain contracts as...more

Eversheds Sutherland (US) LLP

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

Eversheds Sutherland (US) LLP on

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

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