To qualify as a bona fide hedging transaction, the transaction must be clearly identified as a hedging transaction before the end of the day on which the CFC acquired, originated, or entered into the transaction. See §§1.1221-2(f) and 1.954-2(a)(4)(ii)(A) and (B)
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VPLAN - (no access) - 2017-27320 988 regs.pdf, p6
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