
Proposed Regulations Address Applicable Adjustments to Stock and Stock Rights Under Code / August Discussion Draft of Modernization of Derivatives. Subpart F income), passive foreign investment company rules, foreign daß die straddle-Bestimmungen nicht zur Anwendung kommen, da die. mark-to-market accounting, market discount, notional principal contracts, original issue discount, recapitalizations, REMICs, tax hedging rules, straddle rules.