IRS Issues Changes to the Mixed Straddle Regulations

 

On August 2, the IRS issued temporary regulations relating to accrued gain or loss associated with a position that becomes part of section 1092(b)(2) identified mixed straddle.  The temporary regulations segregate pre-identification gain and loss on a mixed straddle position from post-identification gain and loss, preventing taxpayers from using identified mixed straddles as an alternative to selling assets to accelerate gain or loss. For additional information on this development, click here to read the Orrick Alert.