Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series,[1] a special hedging provision is ...
Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity.[1] As a single entity, the risks ...
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There are a large number of well-known ways an FX hedging programme can go wrong, from inefficient netting across organizations’ non-centralized trading, non-uniform accounting procedures and ...
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