26 U.S. Code § 1258 - Recharacterization of gain from certain financial transactions
The term “applicable straddle” means any straddle (within the meaning of section 1092(c)).
In determining the taxpayer’s net investment in any conversion transaction, there shall be included the fair market value of any position which becomes part of such transaction (determined as of the time such position became part of such transaction).
 See References in Text note below.
Section 464(e)(2), referred to in subsec. (d)(5)(C), was repealed by Pub. L. 113–295, div. A, title II, § 221(a)(58)(C)(i), Dec. 19, 2014, 128 Stat. 4047.
2004—Subsec. (d)(1). Pub. L. 108–357 struck out “; except that the term ‘personal property’ shall include stock” before period at end.
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.
Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.
We truncate results at 20000 items. After that, you're on your own.
- Activities to Which Section Applies : 2015-01-02
- Recharacterization of Gain from Certain Transactions : 2015-01-02
LII has no control over and does not endorse any external Internet site that contains links to or references LII.