At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more
7/25/2025
/ Capital Gains ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
Investors ,
IRS ,
Securities ,
Tax Deductions ,
Tax Liability ,
Tax Losses ,
Tax Planning ,
Taxation ,
Wash Sale Rules
What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
6/12/2024
/ Capital Assets ,
Capital Gains ,
Capital Losses ,
Financial Transactions ,
Foreign Currency ,
Foreign Entities ,
Hedges ,
Hedging ,
Internal Revenue Code (IRC) ,
IRS ,
Securities ,
Tax Planning
Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more
6/5/2024
/ Capital Assets ,
Capital Gains ,
Capital Losses ,
Financial Transactions ,
Foreign Currency ,
Foreign Entities ,
Hedges ,
Hedging ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Planning
Which transactions qualify as section 988 transactions?
In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more
Are all foreign currency gains taxable?
No. Under a de minimis exemption individual taxpayers with foreign currency gains of $200 or less on a “personal transaction” do not need to report them....more
Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more
Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more
5/3/2024
/ Business Taxes ,
Capital Gains ,
Capital Losses ,
Corporate Taxes ,
Hedges ,
Hedging ,
Income Taxes ,
Popular ,
Securities Dealers ,
Tax Planning ,
Tax Returns
What are the tax accounting rules for hedges? Whether or not a qualified tax hedge is properly identified, it must be tax accounted for under a method that clearly reflects income. The timing of gains and losses on hedges...more
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
As we’re approaching year end, this is a good time to revisit the tax rules that apply to donating noncash property—including donations of digital assets....more
Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more
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
When it comes to the taxation of stock options, the Internal Revenue Code (Code) does not define capital assets. Rather, it identifies those assets that are not capital assets. ...more