A Second Circuit decision may affect the analysis of whether the modification of a derivative triggers gain or loss.
Gains & Losses
Many times a taxpayer who has purchased distressed debt is unaware of the unfavorable results of the market discount rules.
A new rule eliminates the need for companies to continue to track their windfall pools.
The IRS finalized regulations that implement new SEC rules that change how gains and losses in money market funds are calculated.
The regulations were meant to address a perceived abuse of taxpayers claiming a foreign currency loss by partially legging out of an integrated transaction.
Do not forget to consider the tax accounting method rules (for accrued income or expense items) when dealing with Sec. 382.