26 C.F.R. § 1.1221-2T Hedging transactions (temporary).
Title 26 - Internal Revenue
(a) through (e)(2)(iii) [Reserved] For further guidance, see §1.1221–2(a) through (e)(2)(iii). (iv) Making and revoking the election. Unless the Commissioner otherwise prescribes, the election described in paragraph (e)(2) of §1.1221–2 must be made in a separate statement that provides, “[INSERT NAME AND EMPLOYER IDENTIFICATION NUMBER OF COMMON PARENT] HEREBY ELECTS THE APPLICATION OF §1.1221–2(e)(2) (THE SEPARATE-ENTITY APPROACH).” The statement must also indicate the date as of which the election is to be effective. The election must be filed by including the statement on or with the consolidated group's income tax return for the taxable year that includes the first date for which the election is to apply. The election applies to all transactions entered into on or after the date so indicated. The election may only be revoked with the consent of the Commissioner. (e)(3) through (h) [Reserved] For further guidance, see §1.1221–2(e)(3) through (h). (i) [Reserved] (j) Effective date— (1) Applicability date. This section applies to any original consolidated Federal income tax return due (without extensions) after May 30, 2006. However, a consolidated group may apply this section to any original consolidated Federal income tax return (including any amended return filed on or before the due date (including extensions) of such original return) timely filed on or after May 30, 2006. (2) Expiration date. The applicability of this section will expire on May 26, 2009. [T.D. 9264, 71 FR 30602, May 30, 2006]
Title 26: Internal Revenue
PART 1—INCOME TAXES
General Rules for Determining Capital Gains and Losses
§ 1.1221-2T Hedging transactions (temporary).
