Background on Commodity Tax Straddles and Explanation of S. 626: Scheduled for a Joint Hearing by the Subcommittee on Taxation and Debt Management and the Subcommittee on Energy and Agricultural Taxation of the Committee on Finance on June 12, 1981

Front Cover
U.S. Government Printing Office, 1981 - Commodity exchanges - 30 pages
 

What people are saying - Write a review

We haven't found any reviews in the usual places.

Other editions - View all

Common terms and phrases

Popular passages

Page 28 - November 20, 1951; and (2) the security was not, at any time after the expiration of such 30th day, held by such dealer primarily for sale to customers in the ordinary course of his trade or business.
Page 22 - Gains from futures transactions in any commodity on or subject to the rules of a board of trade or commodity exchange.
Page 17 - The definition of capital gains and losses in section 1222 requires that there be a "sale or exchange" of a capital asset. Court decisions have interpreted this requirement to mean that when a disposition is not a sale or exchange...
Page 28 - For the purposes of this section, the term "security" means any share of stock in any corporation...
Page 22 - However, section 1233 (c) exempts certain options to sell property from the phort sales rules if the option was acquired on the same day as the property and the option, if exercised, is exercised through the sale of the property. Section 1234 provides that gain or loss from the sale or exchange of an option has the same character as gain or loss from the sale or exchange of the property underlying the option, if the property were in the hands of the taxpayer. Gain or loss from closing transactions...
Page 22 - short sale" (ie, where the taxpayer sells borrowed property and later closes the sale by repaying the lender with identical property), any gain or loss on the closing transaction is considered gain or loss from the sale or exchange of a capital asset if the property used to close the short sale is a capital asset in the hands of the taxpayer.
Page 21 - ... are acquired by the taxpayer during the period beginning 30 days before the date of sale and ending 30 days after such date.
Page 26 - For purposes of paragraph (1), the term "interest and carrying charges" means the excess of — (A) the sum of— (i) interest on indebtedness incurred or continued to purchase or carry the personal property, and (ii...
Page 22 - ... gain, and the holding period of the substantially identical property is generally considered to begin on the date of the closing of the short sale (sec. 1233(b)). These rules preclude the taxpayer from "aging...
Page 17 - F.2d 344 (2nd Cir. 1958) . . .] This interpretation has been applied even to dispositions which were economically equivalent to a sale or exchange of a capital asset. Reasons for the Change . . . .Some taxpayers and tax shelter promoters have attempted to exploit court decisions holding that ordinary income or loss results from certain dispositions of property whose sale or exchange would produce capital gain or loss . . . The Committee considers this ordinary loss treatment inappropriate if the...

Bibliographic information