Bona fide hedging transaction.

(12) Bona fide hedging transaction. The term bona fide hedging transaction means a hedging transaction that meets (or that would meet if the specified foreign corporation were a controlled foreign corporation) the requirements of a bona fide hedging transaction described in 1.954-2(a)(4)(ii), except that in the case of a specified foreign corporation that is not a controlled foreign corporation, the identification requirements of 1.954-2(a)(4)(ii)(B) do not apply.

Source

26 CFR § 1.965-1


Scoping language

None
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