Internal Revenue Service September 5, 2013 – Federal Register Recent Federal Regulation Documents

Debt That Is a Position in Personal Property That Is Part of a Straddle
Document Number: 2013-21541
Type: Proposed Rule
Date: 2013-09-05
Agency: Internal Revenue Service, Department of Treasury
This document contains proposed regulations relating to the application of the straddle rules to a debt instrument. The proposed regulations clarify that a taxpayer's obligation under a debt instrument can be a position in personal property that is part of a straddle. The proposed regulations primarily affect taxpayers that issue debt instruments that provide for one or more payments that reference the value of personal property or a position in personal property. This document also provides notice of a public hearing on these proposed regulations.
Debt That Is a Position in Personal Property That Is Part of a Straddle
Document Number: 2013-21540
Type: Rule
Date: 2013-09-05
Agency: Internal Revenue Service, Department of Treasury
This document contains final and temporary regulations relating to the application of the straddle rules to a debt instrument. The temporary regulations clarify that a taxpayer's obligation under a debt instrument can be a position in personal property that is part of a straddle. The temporary regulations primarily affect taxpayers that issue debt instruments that provide for one or more payments that reference the value of personal property or a position in personal property. The text of these temporary regulations also serves as the text of the proposed regulations (REG-111753-12) set forth in the Proposed Rules section in this issue of the Federal Register.