Certain hedges.

(3) Certain hedges. Investment-type property also includes the investment element of a contract that is a hedge (within the meaning of 1.148-4(h)(2)(i)(A)) and that contains a significant investment element because a payment by the issuer relates to a conditional or unconditional obligation by the hedge provider to make a payment on a later date. See 1.148-4(h)(2)(ii) relating to hedges with a significant investment element.


26 CFR § 1.148-1

Scoping language

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