Announcement 2020-4, 2020-17

I.R.B. 667 (April 20, 2020), provides that until further notice, public hearings conducted by the IRS will be held telephonically. Any telephonic hearing will be made accessible to people with disabilities.

Drafting Information

The principal authors of these regulations are D. Peter Merkel and Karen Walny of the Office of Chief Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the Regulations

Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 1 as follows:

PART 1–INCOME TAXES

Paragraph 1. The authority citation for part 1 is amended by adding an entry in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

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Section 1.1256(g)-2 also issued under 26 U.S.C. 1256(g)(2)(B).

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Par. 2. Section 1.1256(g)-2 is added to read as follows:

§1.1256(g)-2 Foreign currency contract defined .

(a) Foreign currency contract . For purposes of section 1256, the term foreign currency contract means a forward contract that—

July 25, 2022 108 Bulletin No. 2022–30

(1) Requires delivery of, or the settlement of which depends on the value of, a foreign currency that is a currency in which positions are also traded through regulated futures contracts;

(2) Is traded in the interbank market; and

(3) Is entered into at arm’s length at a price determined by reference to the price in the interbank market.

(b) Applicability date . This section applies to contracts entered into on or after

[date 30 days after date of publication of the final rule in the Federal Register ].

(Filed by the Office of the Federal Register on July 05, 2022, 8:45 a.m., and published in the issue of the Federal Register for July 06, 2022, 87 F.R. 40168)

Paul J. Mamo, Acting Deputy Commissioner for Ser-

vices and Enforcement.

Bulletin No. 2022–30 109 July 25, 2022