Regulations issued on integrated hedging transactions

The US Treasury Department and the Internal Revenue Service (IRS) have issued temporary regulations (TD 9598) with guidance on certain integrated transactions that involve a foreign currency denominated debt instrument and multiple associated hedging transactions. The regulations were issued under section 988 of the US Internal Revenue Code (IRC) dealing with certain foreign currency transactions.
IRC section 988 and Treas. Reg. section 1.988-5 permit the integration of a qualifying debt…