[Federal Register Volume 78, Number 209 (Tuesday, October 29, 2013)]
[Proposed Rules]
[Page 64430]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2013-25360]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-112815-12]
RIN 1545-BK99
Mixed Straddles; Straddle-by-Straddle Identification Under
Section 1092(b)(2)(A)(i)(I); Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking by cross-reference to temporary
regulations and notice of public hearing; correction.
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SUMMARY: This document contains amendments to proposed regulations
relating to guidance for taxpayers electing to establish a mixed
straddle using straddle-by-straddle identification. These amendments
include a change to the applicability date of the proposed regulations
pursuant to which the proposed regulations would apply to transactions
established after the date of publication of the Treasury decision
adopting these rules as final regulations in the Federal Register. The
amendments to the proposed regulations will affect taxpayers who elect
to establish a mixed straddle using straddle-by-straddle
identification.
DATES: Comments must be received by October 31, 2013. Request to speak
and outlines of topics to be discussed at the public hearing scheduled
for December 4, 2013, at 10 a.m. must be received by October 31, 2013.
ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-112815-12), room
5205, Internal Revenue Service, PO Box 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may be hand-delivered Monday through
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
112815-12), Courier's Desk, Internal Revenue Service, 1111 Constitution
Avenue NW., Washington, DC, or sent electronically via the Federal
eRulemaking Portal at www.regulations.gov (IRS REG-112815-12).
FOR FURTHER INFORMATION CONTACT: Pamela Lew or Robert B. Williams at
(202) 622-3950 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The proposed regulations that are the subject of these amendments
are under section 1092 of the Internal Revenue Code (Code). The text of
temporary regulations (TD 9627), published in the Federal Register on
Friday, August 2, 2013 (78 FR 46807), serves as the text of the
proposed regulations. The proposed regulations (REG-112815-12) were
published in the Federal Register on Friday, August 2, 2013 (78 FR
46854). The proposed regulations were proposed to apply to all
identified mixed straddles established after the date of filing, August
1, 2013.
Need for amendments
The Treasury Department and the IRS received comments raising
concerns about the immediate applicability date of the temporary
regulations. In response to those comments, the Treasury Department and
the IRS are amending the temporary regulations to limit the application
of the identified mixed straddle transaction rules in Sec. 1.1092(b)-
6T to section 1092(b)(2) identified mixed straddles established after
the date of publication of the Treasury decision adopting the rules as
final regulations in the Federal Register. The text of the temporary
regulations, as amended, continues to serve as the text of these
proposed regulations, and this document amends the proposed regulations
to conform to the changes to the temporary regulations. The Treasury
Department and the IRS anticipate finalizing the regulations no later
than the end of the current Priority Guidance Plan year on June 30,
2014, and will as part of that process consider all comments received.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Amendments to the Regulations
Accordingly, 26 CFR part 1 is proposed to be amended as follows:
PART 1--INCOME TAXES
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Paragraph 1. The authority citation for part 1 is amended by adding
entries in numerical order to read as follows:
Authority: 26 U.S.C. 7805 * * *.
Section 1.1092(b)-6 also issued under 26 U.S.C. 1092(b)(1).
Section 1.1092(b)-6 also issued under 26 U.S.C. 1092(b)(2).* * *
0
Par. 2. Section 1.1092(b)-6 is amended by revising the heading to read
as follows:
Sec. 1.1092(b)-6 Mixed straddles; accrued gain and loss associated
with a position that becomes part of a section 1092(b)(2) identified
mixed straddle.
* * * * *
Martin Franks,
Branch Chief, Publications & Regulations Branch, Legal Processing
Division, Associate Chief Counsel, (Procedure & Administration).
[FR Doc. 2013-25360 Filed 10-25-13; 8:45 am]
BILLING CODE 4830-01-P