Notice2026-00335
Agency Information Collection Activities; Comment Request on TD 8649, Netting Rule for Certain Conversion Transactions
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
January 12, 2026
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
In accordance with the Paperwork Reduction Act of 1995, the IRS is inviting comments on the information collection request outlined in this notice.
Full Text
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<title>Federal Register, Volume 91 Issue 7 (Monday, January 12, 2026)</title>
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[Federal Register Volume 91, Number 7 (Monday, January 12, 2026)]
[Notices]
[Pages 1237-1238]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-00335]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
Agency Information Collection Activities; Comment Request on TD
8649, Netting Rule for Certain Conversion Transactions
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of Information Collection; request for comments.
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SUMMARY: In accordance with the Paperwork Reduction Act of 1995, the
IRS is inviting comments on the information collection request outlined
in this notice.
DATES: Written comments should be received on or before March 13, 2026
to be assured of consideration.
ADDRESSES: Direct all written comments to Andres Garcia, Internal
Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC
20224, or by email to <a href="/cdn-cgi/l/email-protection#e3939182cd808c8e8e868d9790a38a9190cd848c95"><span class="__cf_email__" data-cfemail="4c3c3e2d622f2321212922383f0c253e3f622b233a">[email protected]</span></a>. Include OMB Control No.
1545-1452 in the subject line of the message.
FOR FURTHER INFORMATION CONTACT: Requests for additional information or
copies of this collection should be directed to LaNita Van Dyke, (202)
317-6009, or by email to <a href="/cdn-cgi/l/email-protection#baf6dbd4d3cedb94ccdbd4dec3d1dffad3c8c994ddd5cc"><span class="__cf_email__" data-cfemail="afe3cec1c6dbce81d9cec1cbd6c4caefc6dddc81c8c0d9">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION: The IRS, in accordance with the Paperwork
Reduction Act of 1995 (PRA) (44 U.S.C. 3506(c)(2)(A)), provides the
general public and Federal agencies with an opportunity to comment on
proposed, revised, and continuing collections of information. This
helps the IRS assess the impact and minimize the burden of its
information collection requirements. Comments submitted in response to
this notice will be summarized and/or included in the request for OMB
approval. All comments will become a matter of public record, and
viewable on relevant websites. For this reason, please do not include
in your comments information of a confidential nature, such as
sensitive personal information. Comments are invited on: (a) Whether
the collection of information is necessary for the proper performance
of the functions of the agency, including whether the information shall
have practical utility; (b) the accuracy of the agency's estimate of
the burden of the collection of information; (c) ways to enhance the
quality, utility, and clarity of the information to be collected; (d)
ways to minimize the burden of the collection of information on
respondents, including through the use of automated collection
techniques or other forms of information technology; and (e) estimates
of capital or start-up costs and costs of operation, maintenance, and
purchase of services to provide information.
Title: TD 8649, Netting Rule for Certain Conversion Transactions.
OMB Number: 1545-1452.
Regulation Project Number: TD 8649.
Abstract: Internal Revenue Code (IRC) section 1258 recharacterizes
capital gains from conversion transactions as ordinary income to the
extent of the time value element. Treasury Regulations section 1.1258-1
provides that certain gains and losses may be netted for purposes of
determining the amount of gain recharacterized. To be eligible for
netting relief, the taxpayer must identify on its books and records all
the positions that are part of the conversion transaction before the
close of the day on which the positions become part of the conversion
transaction.
Current Actions: There is no change to the existing collection.
Type of Review: Extension of a currently approved collection.
[[Page 1238]]
Affected Public: Individuals and households, business or other for-
profit organizations.
Estimated Number of Responses: 50,000.
Estimated Time per Respondent: 6 minutes.
Estimated Total Annual Burden Hours: 5,000.
Dated: January 6, 2026.
LaNita Van Dyke,
Tax Analyst.
[FR Doc. 2026-00335 Filed 1-9-26; 8:45 am]
BILLING CODE 4830-01-P
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