Page 731 - Large Business IRS Training Guides

Exceptions

• Specified Commodity

of Treas. Reg. §1.965-1(f)(18),
• Held, or, for purposes
to be held, by
an SFC that, in the hands of the SFC is:

• Property
described in section 1221(a)(1) (inventory), or
• Property described in section 1221(a)(8)
(supplies).
• Exception does not apply
with respect to commodities
an SFC in its capacity as a dealer or trader in
held by
commodities.

• Bona Fide Hedging Transaction

• A hedging transaction that meets
the requirements of a
bona fide hedging transaction described in Treas. Reg.

§1.954-2(a)(4)(ii), except

• Where an SFC is
not a CFC, the identification requirements
of
Treas. Reg. §1.954-2(a)(4)(ii)(B) do not apply.

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