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Tax Shelters Foreign Currency

Alston & Bird

Federal Tax Advisory: Mark to Market

Alston & Bird on

In January 2016, the Sixth Circuit reversed the Tax Court and ruled for the taxpayer in Wright v. Commissioner, 809 F. 3d 877 (6th Cir. 2016). If the IRS agrees, the ruling means that foreign currency contracts that are...more

Goulston & Storrs PC

Tax Court Strikes Down “DAD” Loss Importation Tax Shelter

Goulston & Storrs PC on

In consolidated cases known as Kenna Trading LLC, the Tax Court shut down an attempt to contribute foreign currency losses into a US partnership and syndicate the losses to investors by selling partnership interests followed...more

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