591.1.1. For the purposes of subparagraph ii of subparagraph b of the second paragraph of section 591.1, “specified gain” means a gain in respect of the settlement or extinguishment of a foreign currency debt referred to in subparagraph b of the fourth paragraph of that section or that arises under a particular agreement referred to in the fifth paragraph of that section, if the disposing partnership, or any person or partnership with which the particular corporation was not–at any time during which the foreign currency debt was outstanding or the particular agreement was in force, as the case may be–dealing at arm’s length, entered into an agreement that may reasonably be considered to have been entered into for the principal purpose of hedging any foreign exchange exposure arising in connection with the foreign currency debt or the particular agreement.