Credit: 3.0 Credit Hours

Part 2: Special Rules and Regimes Applicable to the Taxation of Financial Transactions (Wednesday, October 17) Part 2 of this series will address a variety of special rules that apply to the taxation of financial transactions. You will learn about the application and consequences of the straddle rules found in IRC §1092. Rules applicable to “constructive sales” of appreciated financial positions under IRC §1259 and the constructive ownership rules of §1260 also will be explained.  

In the second half of this session, you will be introduced with illustrative examples, to three special regimes that apply to the taxation of certain financial transactions:

The application and consequences of mark-to-market rules of IRC §475 for dealers in securities;

The hedging rules designed to match the character and timing of income and deductions for hedging transactions; and

The rules of IRC §988 governing currency transactions.