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Risk Management Hedging

ASKramer Law

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

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When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

ASKramer Law on

What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

ASKramer Law

Business Taxation of Hedging Transactions Part I: Hedging Risks

ASKramer Law on

Enterprise Risk Management is widely used in many industries and businesses. Risk managers use increasingly sophisticated approaches, methods, analytics, and frameworks to manage complex, interrelated, and interconnected...more

Cornerstone Research

Alleged Market Manipulation and the Pre-hedging of Large Trades

Cornerstone Research on

Pre-hedging, or anticipatory hedging, is one of many risk management tools often used in principal-based OTC markets, such as commodities, foreign exchange (FX), or interest rate swap markets. It refers to trading conducted...more

ASKramer Law

Hedging: Favorable Tax Treatment Requires Careful Compliance

ASKramer Law on

It is a common practice for businesses to manage their business price risks by entering into derivative contracts. Because their business activities generate ordinary income and loss, they want to obtain ordinary tax...more

Opportune LLP

Volatile Market Conditions Create Unique Challenges To Managing Price Risk

Opportune LLP on

I had the pleasure of moderating one of the panels at the World Oilman’s Minerals and Royalty Conference (MARC) held in Houston. The title of our session was “Managing Risk”, which of course is an extremely broad topic. We...more

Opportune LLP

Increased Swaption Activity May Present Financial Reporting Challenges for Oil & Gas Companies

Opportune LLP on

Lower natural gas prices are causing E&P companies to get creative with their hedging strategies to lock in near-term cash flows above the dismal levels the market is currently offering. When hedging with options, it’s not...more

Opportune LLP

What You Need To Know Before Starting an ETRM System Implementation Process

Opportune LLP on

Find out everything you need to know before starting an ETRM system implementation. Over the last two decades many energy companies that engaged in the purchase and sale of commodities as a matter of course in transacting...more

Eversheds Sutherland (US) LLP

Two steps closer – FDIC and OCC approve Volcker Rule changes

On August 20, 2019, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) approved amendments to the regulations implementing Section 13 of the Bank Holding Company Act,...more

White & Case LLP

The EU loan syndication impact assessment is out: more competition scrutiny ahead?

White & Case LLP on

Setting the scene The long anticipated European Commission (DG COMP) report on "EU loan syndication and its impact on competition in credit markets" (see here) has finally been published. The study primarily focuses on the...more

Morrison & Foerster LLP

Federal Banking Agencies Issue Recommendations as Part of Their Section 620 Report to Solidify the Safety and Soundness of the...

On September 8, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC,” and...more

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