Mark-and-spread method Clause Samples

Mark-and-spread method. The fol- lowing method may be appropriate for taking into account income, deduction, gain, or loss from ▇▇▇▇▇▇ of aggregate risk: (A) The hedging transactions are marked to market at regular intervals for which the taxpayer has the nec- ▇▇▇▇▇▇ data, but no less frequently than quarterly; and (B) The income, deduction, gain, or loss attributable to the realization or periodic marking to market of hedging transactions is taken into account over the period for which the hedging trans- actions are intended to reduce risk. Al- though the period over which the hedg- ing transactions are intended to reduce risk may change, the period must be reasonable and consistent with the tax- payer’s hedging policies and strategies.