conversion transaction

Defined in 1 place of the United States Code.

For purposes of this section, the term "conversion transaction" means any transaction—

Source

1994–present 26 U.S.C. § 1258Internal Revenue Code · Recharacterization of gain from certain financial transactions · for purposes of this section

For purposes of this section, the term “conversion transaction” means any transaction—

(1) substantially all of the taxpayer’s expected return from which is attributable to the time value of the taxpayer’s net investment in such transaction, and

(2) which is—

(A) the holding of any property (whether or not actively traded), and the entering into a contract to sell such property (or substantially identical property) at a price determined in accordance with such contract, but only if such property was acquired and such contract was entered into on a substantially contemporaneous basis,

(B) an applicable straddle,

(C) any other transaction which is marketed or sold as producing capital gains from a transaction described in paragraph (1), or

(D) any other transaction specified in regulations prescribed by the Secretary.

Source

2013–2018 26 U.S.C. § 1258Internal Revenue Code · Recharacterization of gain from certain financial transactions · for purposes of this section