988 hedging transaction

(2) 988 hedging transaction For purposes of paragraph (1), the term “988 hedging transaction” means any transaction— (A) entered into by the taxpayer primarily— (i) to manage risk of currency fluctuations with respect to property which is held or to be held by the taxpayer, or (ii) to manage risk of currency fluctuations with respect to borrowings made or to be made, or obligations incurred or to be incurred, by the taxpayer, and (B) identified by the Secretary or the taxpayer as being a 988 hedging transaction.

Source

26 USC § 988(d)(2)

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Scoping language

None identified, default scope is assumed to be the parent (subpart J) of this section.

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