Finanse publiczne · 12/27/1994

Netting Rule for Certain Conversion Transactions

The proposed regulations relate to the amount of gain from a conversion transaction position that is subject to recharacterization as ordinary income. The proposed 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 proposed regulations reflect changes to the law made by the Revenue Reconciliation Act of 1993 and affect persons who enter into conversion transactions.