News & Analysis as of

Proposed Regulation Foreign Currency

Eversheds Sutherland (US) LLP

Proposed regulations reduce flexibility of foreign currency mark-to-market election

On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more

McDermott Will & Emery

Weekly IRS Roundup July 25 – July 29, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 25, 2022 – July 29, 2022...more

Cadwalader, Wickersham & Taft LLP

Looking Forward: The IRS Denies 40/60 Treatment for Over-the-Counter Foreign Currency Options under the Mark-to-Market Rules

The IRS has published Proposed Regulations clarifying that for purposes of the mark-to-market rules under section 1256, foreign currency contracts include only foreign currency forward contracts, and that the definition does...more

Eversheds Sutherland (US) LLP

Proposed regulations issued under section 1256 with respect to foreign currency options

Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more

Orrick, Herrington & Sutcliffe LLP

Derivatives In Review - August 2018

On July 12, ISDA initiated a market-wide consultation on technical issues related to new benchmark fallbacks for derivatives referencing certain interbank offered rates, or IBORs, in response to the expected discontinuance of...more

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