Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...more
In This Issue: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives and Modify Certain Other Tax Rules; After Months of Anticipation, Final FATCA Regulations Released; Congress Considers...more
On January 24, 2013, the House Committee on Ways & Means released a discussion draft of legislative provisions (the “Draft” or the “Proposal”) that would make fundamental changes in the taxation of certain financial products....more