Internal Revenue Bulletin: 2013-35
August 26, 2013
Temporary regulations explain how to account for unrealized gain or loss on a position held prior to establishing an identified mixed straddle.
Proposed regulations explain how to account for unrealized gain or loss on a position held prior to establishing an identified mixed straddle. Comments requested by October 31, 2013. A public hearing is scheduled for December 4, 2013.
These regulations propose revisions to examples that illustrate the controlled group rules related to regulated investment companies (RICs) to resolve an issue with how the controlled group rules should be applied in connection with the RIC “asset diversification” test. A public hearing is scheduled for December 9, 2013.
This announcement contains corrections to final regulations and removal of temporary regulations (TD 9622) that were published in the Federal Register on July 3, 2013 (78 FR 39984). The final regulations provide necessary guidance regarding the accelerated inclusion of deferred discharge of indebtedness (also known as cancellation of debt (COD)) income (deferred COD income) and the accelerated deduction of deferred original issue discount (OID) (deferred OID deductions) under section 108(i)(5)(D) (acceleration rules), and the calculation of earnings and profits as a result of an election under section 108(i). In addition, these regulations provide rules applicable to all taxpayers regarding deferred OID deductions under section 108(i) as a result of a reacquisition of an applicable debt instrument by an issuer or related party.
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