§1287. Denial of capital gain treatment for gains on certain obligations not in registered form — Inbound Citations

Citations to 26 U.S.C. § 1287 as a whole

• 26 U.S.C. § 165(j)(3)

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  (3) The Secretary may, by regulations, provide that this subsection and section 1287 shall not apply with respect to obligations held by any person if—

  (A) such person holds such obligations in connection with a trade or business outside the United States,

  (B) such person holds such obligations as a broker dealer (registered under Federal or State law) for sale to customers in the ordinary course of his trade or business,

  (C) such person complies with reporting requirements with respect to ownership, transfers, and payments as the Secretary may require, or

  (D) such person promptly surrenders the obligation to the issuer for the issuance of a new obligation in registered form,

  but only if such obligations are held under arrangements provided in regulations or otherwise which are designed to assure that such obligations are not delivered to any United States person other than a person described in subparagraph (A), (B), or (C).