SECTION 4. APPLICATION
Internal Revenue Bulletin 2004-50 · 2026-10-03 edition · updated 2026-10-04 · United States
.01 In general . For purposes of determining the holding period, the principles of § 246(c)(3) and (c)(4) of the Internal Revenue Code will apply.
.02 Exceptions . In addition to the existing exception in § 1.6011–4(b)(7), the following transactions are not taken into account in determining whether a transaction is a transaction involving a brief asset holding period under § 1.6011–4(b)(7):
(1) In the case of transactions involving solely foreign tax credits, sales made in the ordinary course of the taxpayer’s trade or business of property described in § 1221(a)(1), provided, however, that this exception applies only to credits with re
December 13, 2004 969 2004–50 I.R.B.
26 CFR 601.602. Tax forms and instructions. (Also, Part I, §§ 1, 23, 24, 25A, 32, 42, 59, 62, 63, 68, 132, 135, 137, 146, 1.148–5, 151, 170, 179, 213, 220, 221, 223, 512, 513, 685, 877, 2032A, 2503, 2523, 4261, 6033, 6039F, 6323, 6334, 6601, 7430, 7702B.)
Rev. Proc. 2004–71
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