12:00 – 1:00 pm CDT
On January 24, 2013, the U.S. House Ways and Means Committee Chairman Dave Camp released a discussion draft that, if enacted, would dramatically change the taxation of derivative products entered into by most taxpayers, including individuals, trading firms and businesses. The proposal seeks uniformity for the tax treatment of derivatives by requiring all non-exempt derivative positions to be accounted for on a mark-to-market basis, with resulting gains or losses to be uniformly treated as ordinary income or loss.
McDermott Will & Emery is pleased to invite you to a complimentary webcast focused on the implications of the proposal to various taxpayer groups. Issues to be discussed include:
- Appropriate valuation methods and potential safe harbors
- The repeal of the 60/40 rules for Section 1256 contracts
- The proposed “mixed straddle” that would force taxpayers engaging in risk management transactions to adopt mark-to-market for non-derivative positions—such as debt instruments, stock, currency positions and commodity positions—to the extent offset by derivatives, with disparate treatment of built-in gains versus built-in losses
- The treatment of certain “embedded derivatives” which can result in the bifurcation of a transaction (such as convertible debt instruments) into a derivative and a non-derivative components
We will also discuss the treatment of qualifying business hedging transactions under the proposals, and the limited attempt to provide “relief” from the current hedge identification requirements.
Andrea S. Kramer, Partner
William R. Pomierski, Partner
For more information, please contact McDermott Events.
For a broader discussion of the proposals, click here.
CLE credit for the live presentation of this program is pending in the following states: California, Illinois, New York and Texas. A Uniform Certificate of Attendance will be made available to participants requesting CLE credit in all other states. Please be advised that CLE credit will not be approved for on demand/recorded viewings of this program in the states listed above. Attendees seeking credit in other states should consult their state CLE accrediting agency to determine whether self-study credit can be earned for on demand/recorded viewing of this program.