IRS PLR: Integrated Transaction Election Extension to Meet Identification Requirements Granted (IRC §1275)

A corporate parent received extra time to meet identification requirements in order to elect integration of a qualifying debt instrument and a Treasury Regulations Section 1.1275-6 hedge. According to the representation, Taxpayer intended that the convertible notes it issued be integrated with call options it purchased in the same transaction but, not aware contemporaneously of the specific identification requirements under Treas. Reg. Section 1.1275-6(e), didn’t accordingly take any affirmative action in that regard — and later (following its accounting firm’s advice) prepared documentation intended to comply with the requirements. Among further representations are that no facts have ...