-259-
(B) Exception.--Subparagraph (A) shall
not apply to any gain or loss which is
allocable to a period during which--
(i) the security is described
in subsection (b)(1)(C) (without
regard to subsection (b)(2)),
(ii) the security is held by a
person other than in connection
with its activities as a dealer in
securities, or
(iii) the security is
improperly identified (within the
meaning of subparagraph (A) or (B)
of paragraph (2)).
(e) Regulatory Authority.--The Secretary shall
prescribe such regulations as may be necessary or
appropriate to carry out the purposes of this section,
including rules--
(1) to prevent the use of year-end
transfers, related parties, or other
arrangements to avoid the provisions of this
section, and
(2) to provide for the application of
this section to any security which is a hedge
which cannot be identified with a specific
security, position, right to income, or
liability.
Page: Previous 240 241 242 243 244 245 246 247 248 249 250 251 252 253 254 255 256 257 258 259 Last modified: May 25, 2011