EYEY

US proposed regulations would limit Section 1256 mark-to-market accounting for foreign currency contracts to foreign currency forward contracts

|Tax Alerts, National/Federal Taxation, L ...|United States
United States

  • The proposed regulations confirm that over-the-counter foreign currency options are not subject to mark-to-market treatment under IRC Section 1256.

  • The proposed regulations would explicitly overrule the Sixth Circuit's decision in Wright v. Commissioner and directly affect taxpayers relying on that decision to mark foreign currency options to market under IRC Section 1256.

  • The proposed regulation…

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