“Evolution of Safe Harbor Rules under Section 475,” (with Ann Singer) Derivatives & Financial Instruments, IBFD, Vol. 10, No. 3, May/June 2008, reproduced in Chartered Accountant Practice Journal, Vol. 24, Part 5, December 2008 DFI 2008-7 MTM
On 12 June 2007, the IRS published long-anticipated final safe harbour rules for the valuation of securities and commodities for Sec. 475 mark-to-market accounting purposes. The final regulations are culmination of a process that formally began in 2003 and involved significant industry participation
This article explores the rule-making process by examining the original stated objective of the IRS and the Treasury Department and considers industry input regarding the business and accounting practices of the taxpayers involved. The final regulations implementing the original objectives, as refined by public comment, are discussed as well