Debt That Is a Position in Personal Property That Is Part of a Straddle
other · IRS · Rule · Published 2014-08-27 · Effective 2014-08-27 · 79 FR 51090
Document
Document number
2014-20330
Federal Register citation
79 FR 51090
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2014-08-27
Effective date
2014-08-27
Treasury docket
TD 9691
Abstract
This document contains final regulations relating to the application of the straddle rules to a debt instrument. The final 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 final 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.