The Tax Adviser, July 1st, 1995
Final IRS regulations under IRC section 246 identify when the dividends received tax deduction will be disallowed because the holding period for the stock was not met. Both section 246 and 1092 address the tax treatment of hedging and tax straddles, and the regulations expand the scope of holdings covered to include portfolios with substantial overlap and stock-indexed mutual funds. Section 1092 does not necessarily apply when the deduction under section 246 is disallowed.
The dividends received deduction (DRD) for corporations is disallowed under Sec. 246(c) if the holding period for the sto...
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