Also found in:DictionaryThesaurusMedicalFinancialIdiomsEncyclopediaWikipedia.Related to hedging:hedging betsCurrency Hedgingcautioncircumspection, course of prooection,equivocationhesitancyhesitation, instrumentality of protection,means of protection, method of protection, prevention against loss, prevention of downside, protection against loss,safeguard

Associated concepts:hedge laws, hedges encroaching on another, hedge against inflation, notice of appeal as hedge against loss, persons propertyhedgeverbbe carefulbe cautiousborderboundcirclecircumscribecompassconcealcoverdelimitdelineatedemarcatedividedodgeedgeencloseencompassensphereevadefenceflankgirdleguardhidelimitmark offoutlineplay saferender saferingsafeguardscreensheltershieldsurroundSee also:deceiveequivocateevadeoutbalanceparryprevaricateprotectionsheltertergiversate

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transaction adjustment on Schedule M-l, Reconciliation of Income (Loss) per Books With Income per Return, the taxpayer may not be using a correct accounting method.

Hedge identification and timing rules – traps for the unwary

transaction must reduce the taxpayers own risk, the [final

] regulations do not apply where a taxpayer hedges the risk of another taxpayer, even if that other taxpayer is a related party.

Effective date of proposed consolidated group hedging regulations

Concurrently with the issuance of the regulations, the IRS issued a notice of proposed rulemaking (FI-34-94),(2) relating to the character and time for recognition of certain

transactions entered into by members of an affiliated group filing consolidated returns.

Proposed hedging regulations under Sections 446 and 1221

strategies will have to work with the new standard, banks, insurance companies and utilities in particular will feel its effects.

Thus, there was no need for the IRS to consider whether the taxpayers failure to identify the

transaction was inadvertent within the meaning of Regs.

Letter ruling addresses timing issue for nonidentified hedging transactions

Following on the heels of the Fannie Mae decision, Congress–in the Conference Report to the Omnibus Budget Reconciliation Act of 1993–directed the Treasury Department to study the tax treatment of

transactions and report its findings and recommendations to the congressional tax writing committees.

133, Accounting for Derivative Instruments and

Activities, as amended [AC section D50] (hereinafter referred to as FASB Statement No.

This article examines when ordinary loss treatment will be allowed for

transactions, based on FNMA and the final regulations.

Ordinary treatment now available for hedging transactions

transactions dont always qualify for the hedge accounting prescribed in SFAS 52.

133, Accounting for Derivative Instruments and

Activities, FASB issued an amendment, Accounting for Certain Derivative Instruments and Certain

transactions commonly encountered in business situations.

New hedging regulations designed to minimize character mismatch for tax purposes

anticipated future exposures vividly demonstrate the rampant confusion.

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