[Federal Register Volume 65, Number 9 (Thursday, January 13, 2000)]
[Rules and Regulations]
[Pages 2026-2030]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 00-644]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 8860]
RIN 1545-AP78


Treatment of Income and Expense From Certain Hyperinflationary, 
Nonfunctional Currency Transactions and Certain Notional Principal 
Contracts

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

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SUMMARY: This document contains final regulations regarding the 
treatment of income and deductions arising from certain foreign 
currency transactions denominated in hyperinflationary currencies and 
coordinates section 988 with the section 446 regulations pertaining to 
significant nonperiodic payments. These regulations are intended to 
prevent distortions in computing income and deductions of taxpayers who 
enter into certain transactions in hyperinflationary currencies, and 
nonfunctional currency, notional principal contracts with significant 
nonperiodic payments.

DATES: These regulations are effective February 14, 2000.

FOR FURTHER INFORMATION CONTACT: Roger M. Brown at (202) 622-3830 (not 
a toll-free number) of the Office of the Associate Chief Counsel 
(International) within the Office of the Chief Counsel, Room 4554, 1111 
Constitution Avenue, NW., Washington, DC. 20224.

SUPPLEMENTARY INFORMATION:

Background

    On March 17, 1992, proposed regulations were published in the 
Federal Register at 57 FR 9217 (INTL-15-91). The IRS received two 
written comments on the proposed regulations, which are discussed 
below. No public hearing was held and no requests to speak were 
received. Having considered the comments, the IRS and Treasury 
Department adopt the proposed regulations, as modified by this Treasury 
decision.

Explanation of Provisions

I. Hyperinflationary Instruments

A. Proposed Regulations
    The proposed regulations under Sec. 1.988-2(b)(15) generally 
provided that currency gain or loss on debt instruments and demand 
deposits entered into or acquired when the currency in which the item 
was denominated was hyperinflationary must be realized annually under a 
mark-to-market methodology. For purposes of determining the character 
and source (or allocation) of such currency gain or loss, the gain or 
loss was generally treated as an increase in, or a reduction of, 
interest income or expense.
    The proposed Sec. 1.988-2(b)(15) regulations excluded instruments 
described in section 988(a)(3)(C) (relating to non-dollar, related-
party loans where the rate of interest is at least 10 percentage points 
higher than the Federal mid-term rate) from these rules. Proposed 
regulations Sec. 1.988-2(d)(5) and (e)(7) generally provided that 
currency gain or loss realized with respect to section 988 forward 
contracts, futures contracts, option contracts and similar items (such 
as currency swap contracts) entered into or acquired when the currency 
in which such an item is denominated was hyperinflationary was

[[Page 2027]]

recognized annually under a mark-to-market methodology.

B. Discussion of Comments and Final Regulations

1. Comments and the Treasury and IRS's Responses
    One of the comments responding to the proposed regulations 
criticized the exclusion of loans described in section 988(a)(3)(C) 
from the rules of proposed regulation Sec. 1.988-2(b)(15). The comment 
noted that it was inappropriate to treat related-party loans 
differently from loans between unrelated parties in this context.
    Proposed regulation Sec. 1.988-2(b)(15) excluded loans subject to 
section 988(a)(3)(C) from the mark-to-market rule of the proposed 
regulations because the loans were already subject to mark-to-market 
treatment under section 988(a)(3)(C), which was enacted to prevent 
manipulation of the section 904(a) foreign tax credit limitation 
through related party loans with artificially high interest rates. See 
H. Conf. Rep. No. 841, 99th Cong., 2d Sess. 668 (1986). However, due to 
interest income's U.S. source treatment under section 988(a)(3)(C)(ii), 
mark-to-market treatment under section 988(a)(3)(C), rather than 
Sec. 1.988-2(b)(15), would be, in most cases, more unfavorable to 
taxpayers.
    Since the rules of proposed regulation Sec. 1.988-2(b)(15) were 
consistent with the approach of section 988(a)(3)(C) and prevented 
manipulation of the type Congress addressed in that section, the IRS 
and Treasury agree that transactions described in section 988(a)(3)(C) 
should not be excluded from the mark-to-market rule of the final 
regulations. The IRS and Treasury also have concluded that to the 
extent a debt instrument is subject to the rules of Sec. 1.988-
2(b)(15), the application of section 988(a)(3)(C)'s resourcing rule is 
not necessary. The final regulations reflect these changes.
    The other comment identified the need for coordinating the mark-to-
market regime for hyperinflationary instruments under proposed 
regulation Sec. 1.988-2(b)(15), and the mark-to-market election under 
proposed regulation Sec. 1.988-5(f) for all section 988 transactions. 
The final regulations do not include a rule coordinating these two 
mark-to-market regimes because the mark-to-market election for all 
section 988 transactions is still in proposed form. Accordingly, the 
IRS and Treasury have decided that consideration of the proper 
coordination is most appropriate when the regulations relating to the 
general mark-to-market election for all section 988 transactions are 
finalized.
2. Other Changes to the Final Regulations
(a) Source and Character of Gain or Loss
    The proposed regulations provided that any exchange gain or loss 
realized upon marking to market a debt instrument or a demand deposit 
under proposed regulation Sec. 1.988-2(b)(15)(i) was to be directly 
allocable to the interest income or interest expense from the debt 
instrument or deposit. Accordingly, the gain or loss reduced or 
increased the amount of interest income or interest expense paid or 
accrued during that year with respect to that instrument or deposit. 
Additionally, if realized exchange gain exceeded interest expense of an 
issuer, or realized exchange loss exceeded interest income of a holder 
or depositor, the character and source of such excess amount were to be 
determined under the general rules of Secs. 1.988-3 and 1.988-4.
    The assumption underlying this proposed treatment was that in 
hyperinflationary conditions, high nominal interest rates perform two 
functions: compensate lenders for currency loss attributable to the 
repayment of the principal with a devalued currency, and account for 
borrowers' currency gain on the repayment of the principal with a 
devalued currency. In instances, however, where hyperinflationary 
conditions are subsiding and a lender would actually have currency gain 
on principal repayment (and the borrower would have currency loss on 
principal repayment), these assumptions are no longer appropriate. For 
example, if a lender has currency gain on the marking to market (for 
currency fluctuations only) of the principal of a debt instrument, high 
nominal interest rates would not be compensating the lender for the 
decline in the value of the principal as there would be a gain on the 
principal.
    Accordingly, the final regulations retain the source and character 
rule of the proposed regulations (direct allocation of the exchange 
gain or loss against interest expense or income, respectively) when 
hyperinflationary conditions result in exchange loss to lenders or 
exchange gain to borrowers on the principal amount of a debt instrument 
or deposit. However, where a lender has exchange gain or a borrower has 
exchange loss on the debt instrument--which may occur as 
hyperinflationary conditions subside--the final regulations clarify 
that the exchange gain or loss is not allocated against interest 
expense or income. Rather, the exchange gain or loss is treated under 
the normal currency character and source rules of Secs. 1.988-3 and 
1.988-4. Thus, for example, if an issuer has both interest expense and 
currency loss, the currency loss is sourced and characterized under 
section 988 and does not affect the determination of interest expense.
(b) Synthetic, Non-hyperinflationary Currency Debt Instruments
    The final regulations also make clear that when a debt instrument 
has interest and principal payments that are to be made by reference to 
a non-hyperinflationary currency or item (commonly known as interest 
and principal protection features), the instrument is not marked to 
market under the final section 988 regulations. This is because the 
instrument is, in substance, a synthetic non-hyperinflationary 
instrument and does not experience the distortions associated with a 
hyperinflationary instrument.
(c) Treatment of Hyperinflationary Contracts
    Proposed regulation Sec. 1.988-2(d)(5) generally provided that 
currency gain or loss on derivative contracts described in Sec. 1.988-
1(a)(2)(iii) and denominated in a currency that was hyperinflationary 
at the time the contract was entered into was to be realized annually 
under a mark-to-market methodology. This proposed regulation was issued 
prior to promulgation of the Sec. 1.446-4 regulations (published in the 
Federal Register on July 18, 1994) which requires that, to clearly 
reflect income, the timing of income, deduction, gain or loss on a 
hedge must match the timing of income, deduction, gain or loss on the 
item being hedged. The final regulations modify proposed regulation 
Sec. 1.988-2(d)(5) by providing that Sec. 1.446-4, to the extent 
applicable, will take precedence over proposed regulation Sec. 1.988-
2(d)(5). This is because the IRS and Treasury believe that a clearer 
reflection of income is present where the income and deductions arising 
from an item hedged under Sec. 1.446-4 is matched with the income and 
deductions arising from the hedge. See Sec. 1.446-4(b).
(d) Demand and Time Deposits
    The proposed regulations applied the mark-to-market rules to demand 
deposits denominated in a currency that was hyperinflationary at the 
time the deposit was entered into. Under the final regulations, the 
mark-to-market rules apply to demand and time deposits that provide for 
payments denominated in or by reference to a currency which is 
hyperinflationary at

[[Page 2028]]

the time the taxpayer enters into or otherwise acquires the deposit, or 
whose interest rate reflects hyperinflationary conditions in a country. 
Similar clarifications have been made with respect to the definitions 
of hyperinflationary debt instruments and currency swap contracts.
3. Abusive Transactions
    The Treasury and the IRS are concerned about the use of 
hyperinflationary currencies in transactions motivated by tax 
considerations. Because the direction of exchange rates is relatively 
predictable in hyperinflation economies, some taxpayers have attempted 
to use such currencies in transactions lacking economic substance. See, 
e.g., Agro Science Co. v. Commissioner, T.C. Memo. 1989-687, aff'd, 927 
F.2d 213 (5th Cir.), cert. denied, 502 U.S. 907 (1991). However, 
section 988 may be applied by the IRS in a manner that reflects the 
proper timing, source, and character of income, gain, loss, or expense 
arising from a transaction whose form is not in accordance with its 
economic substance. Secs. 1.988-1(a)(11) and 1.988-2(f); Agro Science 
Co. v. Commissioner, supra. Accordingly, the rules contained in this 
Treasury decision will be applied within the framework of these general 
economic substance principles.

II. Significant Non-periodic Payments and Currency Swaps

    The proposed regulations coordinated section 988 with the section 
446 regulations pertaining to significant nonperiodic payments. The 
final regulations maintain this coordination and clarify that exchange 
gain or loss may be realized on the principal and interest components 
of a significant nonperiodic payment.

III. Proposed Change to Base Period in Notice of Proposed Rulemaking

    Elsewhere in this issue of the Federal Register, the IRS and 
Treasury are publishing a notice of proposed rulemaking that proposes 
to change the period during which inflation rates are measured in the 
determination of whether a currency is hyperinflationary for purposes 
of section 988 (base period). The effect of this change to Sec. 1.988-
1(f) (defining hyperinflationary currency for purposes of section 988) 
is to take into account current year, hyperinflationary conditions, 
rather than determining whether a currency is hyperinflationary based 
on the three years prior to the current year. The proposed change 
relates only to section 988 and not to the dollar approximate separate 
transactions method of Sec. 1.985-3 (DASTM). However, other sections, 
such as Sec. 1.267(f)-1(e) (relating to application of the loss 
disallowance rule of section 267(a)(1) as applied to related party, 
nonfunctional currency loans), which make reference to the section 988 
definition of hyperinflation will be affected.

Special Analyses

    It has been determined that this Treasury decision is not a 
significant regulatory action as defined in Executive Order 12866. 
Therefore, a regulatory assessment is not required. It has also been 
determined that section 553(b) of the Administrative Procedure Act (5 
U.S.C. chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 
6) do not apply to these regulations, and, therefore, a Regulatory 
Flexibility Analysis is not required. Pursuant to section 7805(f) of 
the Internal Revenue Code, the notice of proposed rulemaking preceding 
these regulations was submitted to the Small Business Administration 
for comment on its impact on small businesses.
    Drafting Information: The principal author of these regulations is 
Roger M. Brown of the Office of the Associate Chief Counsel 
(International). However, other personnel from the IRS and Treasury 
Department also participated in their development.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Adoption of the Amendments to the Regulations

    Accordingly, 26 CFR part 1 is amended as follows:

PART 1--INCOME TAXES

    Paragraph 1. The authority citation for part 1 continues to read, 
in part, as follows:

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

    Par. 2. Section 1.988-0 in the Table of Contents is amended by:
    1. The entry for Sec. 1.988-2(b)(14)-(15) is removed.
    2. An entry for Sec. 1.988-2(b)(14) is added.
    3. An entry for Sec. 1.988-2(b)(15) is added.
    4. The entry for Sec. 1.988-2(d)(5) is revised.
    5. The entry for Sec. 1.988-2(e)(7) is revised.
    The revisions and additions read as follows:


Sec. 1.988-0  Taxation of gain or loss from a section 988 transaction; 
Table of Contents.

* * * * *


Sec. 1.988-2  Recognition and computation of exchange gain or loss

* * * * *
    (b) * * *
    (14) [Reserved]
    (15) Debt instruments and deposits denominated in 
hyperinflationary currencies.
* * * * *
    (d) ***
    (5) Hyperinflationary contracts.
    (e) * * *
    (7) Special rules for currency swap contracts in 
hyperinflationary currencies.
* * * * *
    Par. 3. Section 1.988-2 is amended by:
    1. Adding paragraph (b)(15).
    2. Adding paragraph (d)(5).
    3. Adding paragraph (e)(3)(iv).
    4. Adding paragraph (e)(7).
    The additions read as follows:


Sec. 1.988-2  Recognition and computation of exchange gain or loss.

* * * * *
    (b) * * *
    (14) [Reserved]
    (15) Debt instruments and deposits denominated in hyperinflationary 
currencies--(i) In general. If a taxpayer issues, acquires, or 
otherwise enters into or holds a hyperinflationary debt instrument (as 
defined in paragraph (b)(15)(vi)(A) of this section) or a 
hyperinflationary deposit (as defined in paragraph (b)(15)(vi)(B) of 
this section) on which interest is paid or accrued that is denominated 
in (or determined by reference to) a nonfunctional currency of the 
taxpayer, then the taxpayer shall realize exchange gain or loss with 
respect to such instrument or deposit for its taxable year determined 
by reference to the change in exchange rates between--
    (A) The later of the first day of the taxable year, or the date the 
instrument was entered into (or an amount deposited); and
    (B) The earlier of the last day of the taxable year, or the date 
the instrument (or deposit) is disposed of or otherwise terminated.
    (ii) Only exchange gain or loss is realized. No gain or loss is 
realized under paragraph (b)(15)(i) by reason of factors other than 
movement in exchange rates, such as the creditworthiness of the debtor.
    (iii) Special rule for synthetic, non-hyperinflationary currency 
debt instruments--(A) General rule. Paragraph (b)(15)(i) does not apply 
to a debt instrument that has interest and principal payments that are 
to be made by reference to a currency or item that does not reflect 
hyperinflationary conditions in a country (within the meaning of 
Sec. 1.988-1(f)).

[[Page 2029]]

    (B) Example. Paragraph (b)(15)(iii)(A) is illustrated by the 
following example:

    Example. When the Turkish lira (TL) is a hyperinflationary 
currency, A, a U.S. corporation with the U.S. dollar as its 
functional currency, makes a 5 year, 100,000 TL-denominated loan to 
B, an unrelated corporation, at a 10% interest rate when 1,000 TL 
equals $1. Under the terms of the debt instrument, B must pay 
interest annually to A in amount of Turkish lira that is equal to 
$100. Also under the terms of the debt instrument, B must pay A upon 
maturity of the debt instrument an amount of Turkish lira that is 
equal to $1,000. Although the principal and interest are payable in 
a hyperinflationary currency, the debt instrument is a synthetic 
dollar debt instrument and is not subject to paragraph (b)(15)(i) of 
this section.

    (iv) Source and character of gain or loss--(A) General rule for 
hyperinflationary conditions. The rules of this paragraph 
(b)(15)(iv)(A) shall apply to any taxpayer that is either an issuer of 
(or obligor under) a hyperinflationary debt instrument or deposit and 
has currency gain on such debt instrument or deposit, or a holder of a 
hyperinflationary debt instrument or deposit and has currency loss on 
such debt instrument or deposit. For purposes of subtitle A of the 
Internal Revenue Code, any exchange gain or loss realized under 
paragraph (b)(15)(i) of this section is directly allocable to the 
interest expense or interest income, respectively, from the debt 
instrument or deposit (computed under this paragraph (b)), and 
therefore reduces or increases the amount of interest income or 
interest expense paid or accrued during that year with respect to that 
instrument or deposit. With respect to a debt instrument or deposit 
during a taxable year, to the extent exchange gain realized under 
paragraph (b)(15)(i) of this section exceeds interest expense of an 
issuer, or exchange loss realized under paragraph (b)(15)(i) of this 
section exceeds interest income of a holder or depositor, the character 
and source of such excess amount shall be determined under Secs. 1.988-
3 and 1.988-4.
    (B) Special rule for subsiding hyperinflationary conditions. If the 
taxpayer is an issuer of (or obligor under) a hyperinflationary debt 
instrument or deposit and has currency loss, or if the taxpayer is a 
holder of a hyperinflationary debt instrument or deposit and has 
currency gain, then for purposes of subtitle A of the Internal Revenue 
Code, the character and source of the currency gain or loss is 
determined under Secs. 1.988-3 and 1.988-4. Thus, if an issuer has both 
interest expense and currency loss, the currency loss is sourced and 
characterized under section 988, and does not affect the determination 
of interest expense.
    (v) Adjustment to principal or basis. Any exchange gain or loss 
realized under paragraph (b)(15)(i) of this section is an adjustment to 
the functional currency principal amount of the issuer, functional 
currency basis of the holder, or the functional currency amount of the 
deposit. This adjusted amount or basis is used in making subsequent 
computations of exchange gain or loss, computing the basis of assets 
for purposes of allocating interest under Secs. 1.861-9T through 1.861-
12T and 1.882-5, or making other determinations that may be relevant 
for computing taxable income or loss.
    (vi) Definitions--(A) Hyperinflationary debt instrument. A 
hyperinflationary debt instrument is a debt instrument that provides 
for--
    (1) Payments denominated in or determined by reference to a 
currency that is hyperinflationary (as defined in Sec. 1.988-1(f)) at 
the time the taxpayer enters into or otherwise acquires the debt 
instrument; or
    (2) Payments denominated in or determined by reference to a 
currency that is hyperinflationary (as defined in Sec. 1.988-1(f)) 
during the taxable year, and the terms of the instrument provide for 
the adjustment of principal or interest payments in a manner that 
reflects hyperinflation. For example, a debt instrument providing for a 
variable interest rate based on local conditions and generally 
responding to changes in the local consumer price index will reflect 
hyperinflation.
    (B) Hyperinflationary deposit. A hyperinflationary deposit is a 
demand or time deposit or similar instrument issued by a bank or other 
financial institution that provides for--
    (1) Payments denominated in or determined by reference to a 
currency that is hyperinflationary (as defined in Sec. 1.988-1(f)) at 
the time the taxpayer enters into or otherwise acquires the deposit; or
    (2) Payments denominated in or determined by reference to a 
currency that is hyperinflationary (as defined in Sec. 1.988-1(f)) 
during the taxable year, and the terms of the deposit provide for the 
adjustment of the deposit amount or interest payments in a manner that 
reflects hyperinflation.
    (vii) Interaction with other provisions--(A) Interest allocation 
rules. In determining the amount of interest expense, this paragraph 
(b)(15) applies before Secs. 1.861-9T through 1.861-12T, and 1.882-5.
    (B) DASTM. With respect to a qualified business unit that uses the 
United States dollar approximate separate transactions method of 
accounting described in Sec. 1.985-3, paragraph (b)(15)(i) of this 
section does not apply.
    (C) Interaction with section 988(a)(3)(C). Section 988(a)(3)(C) 
does not apply to a debt instrument subject to the rules of paragraph 
(b)(15)(i) of this section.
    (D) Hedging rules. To the extent Sec. 1.446-4 or 1.988-5 apply, the 
rules of paragraph (b)(15)(i) of this section will not apply. This 
paragraph (b)(15)(vii)(D) does not apply if the application of 
Sec. 1.988-5 results in hyperinflationary debt instrument or deposit 
described in paragraph (b)(15)(vi)(A) or (B) of this section.
    (viii) Effective date. This paragraph (b)(15) applies to 
transactions entered into after February 14, 2000.
* * * * *
    (d) * * *
    (5) Hyperinflationary contracts--(i) In general. If a taxpayer 
acquires or otherwise enters into a hyperinflationary contract (as 
defined in paragraph (d)(5)(ii) of this section) that has payments to 
be made or received that are denominated in (or determined by reference 
to) a nonfunctional currency of the taxpayer, then the taxpayer shall 
realize exchange gain or loss with respect to such contract for its 
taxable year determined by reference to the change in exchange rates 
between--
    (A) The later of the first day of the taxable year, or the date the 
contract was acquired or entered into; and
    (B) The earlier of the last day of the taxable year, or the date 
the contract is disposed of or otherwise terminated.
    (ii) Definition of hyperinflationary contract. A hyperinflationary 
contract is a contract described in paragraph (d)(1) of this section 
that provides for payments denominated in or determined by reference to 
a currency that is hyperinflationary (as defined in Sec. 1.988-1(f)) at 
the time the taxpayer acquires or otherwise enters into the contract.
    (iii) Interaction with other provisions--(A) DASTM. With respect to 
a qualified business unit that uses the United States dollar 
approximate separate transactions method of accounting described in 
Sec. 1.985-3, this paragraph (d)(5) does not apply.
    (B) Hedging rules. To the extent Sec. 1.446-4 or 1.988-5 apply, 
this paragraph (d)(5) does not apply.
    (C) Adjustment for subsequent transactions. Proper adjustments must 
be made in the amount of any gain or loss subsequently realized for 
gain or loss taken into account by reason of this paragraph (d)(5).

[[Page 2030]]

    (iv) Effective date. This paragraph (d) (5) is applicable to 
transactions acquired or otherwise entered into after February 14, 
2000.
    (e) * * *
    (3) * * *
    (iv) Coordination with Sec. 1.446-3(g)(4) regarding swaps with 
significant nonperiodic payments. The rules of Sec. 1.446-3(g)(4) apply 
to any currency swap with a significant nonperiodic payment. Section 
1.446-3(g)(4) applies before this paragraph (e)(3). Thus, if 
Sec. 1.446-3(g)(4) applies, currency gain or loss may be realized on 
the loan. This paragraph (e)(3)(iv) applies to transactions entered 
into after February 14, 2000.
* * * * *
    (7) Special rules for currency swap contracts in hyperinflationary 
currencies--(i) In general. If a taxpayer enters into a 
hyperinflationary currency swap (as defined in paragraph (e)(7)(iv) of 
this section), then the taxpayer realizes exchange gain or loss for its 
taxable year with respect to such instrument determined by reference to 
the change in exchange rates between--
    (A) The later of the first day of the taxable year, or the date the 
instrument was entered into (by the taxpayer); and
    (B) The earlier of the last day of the taxable year, or the date 
the instrument is disposed of or otherwise terminated.
    (ii) Adjustment to principal or basis. Proper adjustments are made 
in the amount of any gain or loss subsequently realized for gain or 
loss taken into account by reason of this paragraph (e)(7).
    (iii) Interaction with DASTM. With respect to a qualified business 
unit that uses the United States dollar approximate separate 
transactions method of accounting described in Sec. 1.985-3, this 
paragraph (e)(7) does not apply.
    (iv) Definition of hyperinflationary currency swap contract. A 
hyperinflationary currency swap contract is a currency swap contract 
that provides for--
    (A) Payments denominated in or determined by reference to a 
currency that is hyperinflationary (as defined in Sec. 1.988-1(f)) at 
the time the taxpayer enters into or otherwise acquires the currency 
swap; or
    (B) Payments that are adjusted to take into account the fact that 
the currency is hyperinflationary (as defined in Sec. 1.988-1(f)) 
during the current taxable year. A currency swap contract that provides 
for periodic payments determined by reference to a variable interest 
rate based on local conditions and generally responding to changes in 
the local consumer price index is an example of this latter type of 
currency swap contract.
    (v) Special effective date for nonfunctional hyperinflationary 
currency swap contracts. This paragraph (e)(7) applies to transactions 
entered into after February 14, 2000.
* * * * *

    Approved: December 13, 1999.
Robert E. Wenzel,
Deputy Commissioner of Internal Revenue.
Jonathan Talisman,
Acting Assistant Secretary of the Treasury.
[FR Doc. 00-644 Filed 1-12-00; 8:45 am]
BILLING CODE 4830-01-P