Regulations Under Section 1258 of the
Internal Revenue Code of 1986; Netting
Rule For Certain Conversion Transactions

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 602 [TD 8649] RIN 1545-AS87

TITLE: Regulations Under Section 1258 of the Internal Revenue Code of 1986; Netting Rule For Certain Conversion Transactions

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations relating to conversion transactions. These regulations provide that certain gains and losses from positions of the same conversion transaction may be netted for purposes of determining the amount of gain that is recharacterized as ordinary income. These regulations reflect changes to the law made by the Revenue Reconciliation Act of 1993 and affect persons who enter into conversion transactions.

EFFECTIVE DATES: These regulations are effective [INSERT DATE OF PUBLICATION IN THE FEDERAL REGISTER]. For applicability of these regulations, see EFFECTIVE DATES under the SUPPLEMENTARY INFORMATION part of the preamble.

FOR FURTHER INFORMATION CONTACT: Alan B. Munro, (202) 622-3950 (not a toll-free number).

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