Per TaxAnalysts on July 17, 3014, “The IRS has issued final regulations relating to section 1092 identified mixed straddles established after Aug. 18, 2014, explaining how to account for unrealized gain or loss on a position held by a taxpayer before the time the taxpayer establishes a mixed straddle using straddle-by-straddle identification. (T.D. 9678).”
Straddle rules are very complex. We suggest a consultation with our tax attorney.