Everything Compliance-Episode 12
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more
Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more
Are all foreign currency gains taxable? No. Under a de minimis exemption individual taxpayers with foreign currency gains of $200 or less on a “personal transaction” do not need to report them....more
Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more
On 28 February, 1 March and 5 March 2022, the Russian President signed Decrees on special economic measures in connection with so-called "unfriendly" (as such term is used in the Decrees) actions by the USA and the foreign...more
Russian authorities are taking measures on several fronts to support financial markets and keep liquid assets in Russia, including a new set of countermeasures introduced by President Vladimir Putin. Russia’s Central Bank is...more
In response to the economic sanctions and export controls imposed on Russia by the US, EU, UK and other major economies, Russia imposed measures and countermeasures....more
On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia, National Wealth Fund, Ministry of Finance, and Russian Direct Investment Fund, dramatically increasing the economic impact of...more
With the rise of digital currencies, it was inevitably going to attract the attention of governments. Not just in the regulatory sense, but also in terms of utilization. The blockchain technology underlying these virtual...more
The Financial Industry Regulatory Authority is not known for its aggressive enforcement record. But that may be changing. FINRA recently fined BNP Paribas for $15 million for anti-money laundering deficiencies in the...more
Last week’s wild economic ride combined with China’s currency-devaluing response (and, arguably, months more of trade-war-driven global uncertainty) led to the worst day on Wall Street since last December, with the Dow...more