News & Analysis as of

Capital Gains Derivatives

Eversheds Sutherland (US) LLP

Proposed regulations issued under section 1256 with respect to foreign currency options

Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more

Cadwalader, Wickersham & Taft LLP

Keep Your Eyes on Mark-to-Market

We report elsewhere in this issue on Senate Finance Committee Chair Ron Wyden's (D-Ore.) proposed mark-to-market tax on billionaires. On August 5, 2021, Wyden also introduced the Modernization of Derivatives Tax Act of 2021...more

Akin Gump Strauss Hauer & Feld LLP

UK Summer Budget 2015

On Wednesday, 8 July 2015, George Osborne delivered the UK Summer Budget. The first Budget of the new Conservative government (and the second Budget of 2015), the Summer Budget is wide-ranging in scope and potentially...more

Morrison & Foerster LLP

Moving from the Academic to the Legislative: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives...

BACKGROUND - For many years, academics have proposed that the U.S. replace the current hodge-podge U.S. federal income tax rules applicable to financial derivatives with a “mark-to-market” regime. In the first...more

Eversheds Sutherland (US) LLP

Legal Alert: Camping on "The Street": A First Step in the Reform of the Taxation of Financial Instruments and Products

On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain financial instruments and products (the Camp Draft). In brief, the Camp Draft: ...more

McDermott Will & Emery

Focus on Private Equity -- Issue 2, October 2012

McDermott Will & Emery on

In This Issue: Excerpt from Year-End Tax Planning Steps for Private Equity The last time the Bush tax cuts were set to expire at the end of 2010, we saw numerous clients scrambling to execute end-of-the-year...more

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