Items that are not securities.
Items that are not securities. The following items are not securities within the meaning of section 475(c)(2) with respect to a taxpayer and, therefore, are not subject to section 475
(1) A security (determined without regard to this paragraph (a)) if section 1032 prevents the taxpayer from recognizing gain or loss with respect to that security;
(2) A debt instrument issued by the taxpayer (including a synthetic debt instrument, within the meaning of § 1.1275–6(b)(4), that § 1.1275–6(b) treats the taxpayer as having issued); or
(3) A REMIC residual interest, or an interest or arrangement that is determined by the Commissioner to have substantially the same economic effect, if the residual interest or the interest or arrangement is acquired on or after January 4, 1995.