Guidance Regarding the Definition of Foreign Personal Holding Company Income
other · IRS · Rule · Published 2003-01-31 · Effective 2003-01-31 · 68 FR 4916
Document
Document number
03-2209
Federal Register citation
68 FR 4916
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
other
Sub-agency
IRS
Publication date
2003-01-31
Effective date
2003-01-31
Treasury docket
TD 9039
Abstract
This document contains final regulations that provide that gain or loss arising from certain commodities hedging transactions and currency gain or loss arising from certain interest-bearing liabilities do not constitute (or are not netted against) foreign personal holding company income. This treatment is implemented because the applicable commodities hedging transactions and interest-bearing liabilities typically offset transactions that do not generate foreign personal holding company income.