Treasury delays effective date of new temporary regulations addressing identified mixed straddles

Insurance Tax Bulletin

On August 1, 2013, the IRS issued temporary Treasury regulations that prohibited taxpayers from using identified mixed straddles executed after August 1, 2013 as an investment strategy to recognize built-in capital gains in order to offset capital loss carryforwards. These temporary regulations applied to all identified mixed straddle transactions entered into after August 1, 2013. On October 25, 2013, the IRS granted limited relief from the regulations by extending the effective date of the new temporary regulations until the date that they are finalized.



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