{"data":{"id":"us/26-cfr-1.1256-e-1","jurisdiction":"us","citation":"26 CFR 1.1256(e)-1","heading":"(e)-1 Identification of hedging transactions.","body":"(a) Identification and recordkeeping requirements. Under section 1256(e)(2), a taxpayer that enters into a hedging transaction must identify the transaction as a hedging transaction before the close of the day on which the taxpayer enters into the transaction.\n(b) Requirements for identification. The identification of a hedging transaction for purposes of section 1256(e)(2) must satisfy the requirements of § 1.1221-2(f)(1). Solely for purposes of section 1256(f)(1), however, an identification that does not satisfy all of the requirements of § 1.1221-2(f)(1) is nevertheless treated as an identification under section 1256(e)(2).\n(c) Consistency with § 1.1221-2. Any identification for purposes of § 1.1221-2(f)(1) is also an identification for purposes of this section. If a taxpayer satisfies the requirements of § 1.1221-2(g)(1)(ii), the transaction is treated as if it were not identified as a hedging transaction for purposes of section 1256(e)(2).\n(d) Effective date. The rules of this section apply to transactions entered into on or after March 20, 2002.","path":["Title 26—Internal Revenue","CHAPTER I—INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY","SUBCHAPTER A—INCOME TAX","PART 1—INCOME TAXES"],"source_url":"https://www.ecfr.gov/api/versioner/v1/full/2026-08-25/title-26.xml","current_through":"2026-08-25","vintage":"","retrieved_at":"2026-08-27T02:25:11Z","sha256":"b2e904afc2ff4d317732278b70ccdd40e79e2fd241d24df386985082a23e179c","source_id":"us-cfr","stale":true,"prev":"us/26-cfr-1.1254-6","next":"us/26-cfr-1.1256-e-2"},"notice":"GroundRules: Original legal text. Not legal advice."}