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Section 1256 and Foreign Currency Derivatives
Section 1256 and Foreign Currency Derivatives Viva Hammer1 Mark-to-market taxation was considered “a fundamental departure from the concept of income realization in the U.S. tax law”2 when it was introduced in 1981. Congress was only game to propose the concept because of rampant “straddle” shelters that were undermining the U.S. tax system and commodities derivatives markets. Early in tax history, the Supreme Court articulated the realization principle as a Constitutional limitation on Congress’ taxing power. But in 1981, lawmakers makers felt confident imposing mark-to-market on exchange traded futures contracts because of the exchanges’ system of variation margin. However, when in 1982 non-exchange foreign currency traders asked to come within the ambit of mark-to-market taxation, Congress acceded to their demands even though this market had no equivalent to variation margin. This opportunistic rather than policy-driven history has spawned a great debate amongst tax practitioners as to the scope of the mark-to-market rule governing foreign currency contracts. Several recent cases have added fuel to the debate. The Straddle Shelters of the 1970s Straddle shelters were developed to exploit several structural flaws in the U.S. tax system: (1) the vast gulf between ordinary income tax rate (maximum 70%) and long term capital gain rate (28%), (2) the arbitrary distinction between capital gain and ordinary income, making it relatively easy to convert one to the other, and (3) the non- economic tax treatment of derivative contracts. Straddle shelters were so pervasive that in 1978 it was estimated that more than 75% of the open interest in silver futures were entered into to accommodate tax straddles and demand for U.S. -
Pfsvx Statement of Additional
LITMAN GREGORY FUNDS TRUST PartnerSelect SBH Focused Small Value Fund - Institutional Class – PFSVX STATEMENT OF ADDITIONAL INFORMATION Dated July 23, 2020 This Statement of Additional Information (“SAI”) is not a prospectus, and it should be read in conjunction with the prospectus dated July 23, 2020, as it may be amended from time to time, of PartnerSelect SBH Focused Small Value Fund (the “Focused Small Value Fund” or the “Fund”), a series of the Litman Gregory Funds Trust (the “Trust”), formerly known as the Masters’ Select Funds Trust until August 2011 and the Masters’ Select Investment Trust until December 1997. Litman Gregory Fund Advisors, LLC (the “Advisor” or “Litman Gregory”) is the investment advisor of the Fund. The Advisor has retained an investment manager as sub-advisor (the “Sub- Advisor”), which is responsible for portfolio management of the Fund’s assets. A copy of the Fund’s prospectus and the Trust’s most recent annual report may be obtained from the Trust without charge at 1676 N. California Blvd., Suite 500, Walnut Creek, California 94596, telephone 1-800-960-0188. The Trust’s audited financial statements for the fiscal year ended December 31, 2019 are incorporated by reference to the Trust’s Annual Report for the fiscal year ended December 31, 2019. The Fund is not included in the Trust’s most recent Annual Report because it commenced investment operations after December 31, 2019, but will be included in the Trust’s next report to shareholders following such date. 1 TABLE OF CONTENTS FUND HISTORY .......................................................................................................................................................... 3 INVESTMENT OBJECTIVES, POLICIES AND RISKS ........................................................................................... -
Decreto Del Direttore Amministrativo N
Corso di Laurea magistrale (ordinamento ex D.M. 270/2004) in Economia e Finanza Tesi di Laurea Gli strumenti derivati ed il loro utilizzo in azienda: l’importanza di gestirne i vantaggi e le complessità Relatore Prof. Guido Massimiliano Mantovani Laureando Ambra Moschini Matricola:835318 Anno Accademico 2013 / 2014 Sessione straordinaria 2 Indice Indice delle Figure ....................................................................................................................... 6 Indice delle Tavole ...................................................................................................................... 7 Introduzione ................................................................................................................................. 8 Capitolo 1 - Il concetto di rischio ............................................................................................. 11 1.1. Definizione .................................................................................................................. 12 1.2. La percezione del rischio in azienda ........................................................................... 16 1.3. Identificazione delle categorie di rischio .................................................................... 24 1.3.1. Rischi finanziari .................................................................................................. 26 1.3.1.1. Rischio di mercato ............................................................................................... 28 1.3.1.1.1. Rischio di -
The Federal Government's Use of Interest Rate Swaps and Currency
The Federal Government’s Use of Interest Rate Swaps and Currency Swaps John Kiff, Uri Ron, and Shafiq Ebrahim, Financial Markets Department • Interest rate swaps and currency swaps are swap agreement is a contract in which contracts in which counterparties agree to two counterparties arrange to exchange exchange cash flows according to a pre-arranged cash-flow streams over a period of time A according to a pre-arranged formula. Two formula. In its capacity as fiscal agent for the federal government, the Bank of Canada has of the most common swap agreements are interest rate carried out swap agreements since fiscal year swaps and currency swaps. In an interest rate swap, counterparties exchange a series of interest payments 1984/85. denominated in the same currency; in a currency • The government uses these swap agreements to swap, counterparties exchange a series of interest pay- obtain cost-effective financing, to fund its foreign ments denominated in different currencies. There is exchange reserves, and to permit flexibility in no exchange of principal in an interest rate swap, but a managing its liabilities. principal payment is exchanged at the beginning and • To minimize its exposure to counterparty credit upon maturity of a currency-swap agreement. risk, the government applies strict credit-rating The swaps market originated in the late 1970s, when criteria and conservative exposure limits based on simultaneous loans were arranged between British a methodology developed by the Bank for and U.S. entities to bypass regulatory barriers on the International Settlements. movement of foreign currency. The first-known foreign currency swap transaction was between the World • Between fiscal 1987/88 and 1994/95, the Bank and IBM in August 1981 and was arranged by government used domestic interest rate swaps to Salomon Brothers (Das 1994, 14–36). -
European Tracker of Financing Measures
20 May 2020 This publication provides a high level summary of the targeted measures taken in the United Kingdom and selected European jurisdictions, designed to support businesses and provide relief from the impact of COVID-19. This information has been put together with the assistance of Wolf Theiss for Austria, Stibbe for Benelux, Kromann Reumert for Denmark, Arthur Cox for Ireland, Gide Loyrette Nouel for France, Noerr for Germany, Gianni Origoni, Grippo, Capelli & Partners for Italy, BAHR for Norway, Cuatrecasas for Portugal and Spain, Roschier for Finland and Sweden, Bär & Karrer AG for Switzerland. We would hereby like to thank them very much for their assistance. Ropes & Gray is maintaining a Coronavirus resource centre at www.ropesgray.com/en/coronavirus which contains information in relation to multiple geographies and practices with our UK related resources here. JURISDICTION PAGE EU LEVEL ...................................................................................................................................................................................................................... 2 UNITED KINGDOM ....................................................................................................................................................................................................... 8 IRELAND .................................................................................................................................................................................................................... -
DEPARTMENT of the TREASURY Determination of Foreign Exchange
This document has been submitted to the Office of the Federal Register (OFR) for publication and is pending placement on public display at the OFR and publication in the Federal Register. The document may vary slightly from the published document if minor editorial changes have been made during the OFR review process. Upon publication in the Federal Register, the regulation can be found at http://www.gpoaccess.gov/fr/, www.regulations.gov, and at www.treasury.gov. The document published in the Federal Register is the official document. DEPARTMENT OF THE TREASURY Determination of Foreign Exchange Swaps and Foreign Exchange Forwards under the Commodity Exchange Act AGENCY: Department of the Treasury, Departmental Offices. ACTION: Notice of Proposed Determination. SUMMARY: The Commodity Exchange Act (―CEA‖), as amended by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (―Dodd-Frank Act‖), authorizes the Secretary of the Treasury (―Secretary‖) to issue a written determination exempting foreign exchange swaps, foreign exchange forwards, or both, from the definition of a ―swap‖ under the CEA. The Secretary proposes to issue a determination that would exempt both foreign exchange swaps and foreign exchange forwards from the definition of ―swap,‖ in accordance with the relevant provisions of the CEA and invites comment on the proposed determination, as well as the factors supporting such a determination. DATES: Written comments must be received on or before [INSERT DATE THAT IS 30 DAYS AFTER PUBLICATION IN THE FEDERAL REGISTER], to be assured of consideration. ADDRESSES: Submission of Comments by mail: You may submit comments to: Office of Financial Markets, Department of the Treasury, 1500 Pennsylvania Avenue N.W., Washington, DC, 20220. -
Currency Swaps Basis Swaps Basis Swaps Involve Swapping One Floating Index Rate for Another
Advanced forms of currency swaps Basis swaps Basis swaps involve swapping one floating index rate for another. Banks may need to use basis swaps to arrange a currency swap for the customers. Example A customer wants to arrange a swap in which he pays fixed dollars and receives fixed sterling. The bank might arrange 3 other separate swap transactions: • an interest rate swap, fixed rate against floating rate, in dollars • an interest rate swap, fixed sterling against floating sterling • a currency basis swap, floating dollars against floating sterling Hedging the Bank’s risk Exposures arise from mismatched principal amounts, currencies and maturities. Hedging methods • If the bank is paying (receiving) a fixed rate on a swap, it could buy (sell) government bonds as a hedge. • If the bank is paying (receiving) a variable, it can hedge by lending (borrowing) in the money markets. When the bank finds a counterparty to transact a matching swap in the opposite direction, it will liquidate its hedge. Multi-legged swaps In a multi-legged swap a bank avoids taking on any currency risk itself by arranging three or more swaps with different clients in order to match currencies and amounts. Example A company wishes to arrange a swap in which it receives floating rate interest on Australian dollars and pays fixed interest on sterling. • a fixed sterling versus floating Australian dollar swap with the company • a floating Australian dollar versus floating dollar swap with counterparty A • a fixed sterling versus dollar swap with counterparty B Amortizing swaps The principal amount is reduced progressively by a series of re- exchanging during the life of the swap to match the amortization schedule of the underlying transaction. -
Currency Derivatives
Customer copy 1 (3) INFORMATION SHEET, as stipulated in the Swedish Securities Market Act - November 2012 Currency derivatives Introduction • The price of the option is called the premium and is paid by the holder of the option (the buyer) to the issuer of the option (the Currency derivatives are complex financial instruments and this is a seller). collective term for instruments such as options, futures and swaps. • Currency options are typically European style. This means that the The derivative's value is based on the underlying asset; the price is option can only be utilised or settled for cash on the expiry date. influenced partly by the interest rate, remaining maturity and volatility “American options” can be exercised by the holder during the term to (describes how much the underlying asset is estimated to vary during the expiration. term to maturity). When the underlying currency’s value rises or falls, the relative value of The characteristic of a derivative is that it is linked to events or conditions an investment in a currency option can be influenced more than the at a specified time or period in the future. relative value of an investment in the underlying currency (leverage effect). Different derivative instruments have different risk levels and factors that affect the return. It is therefore important that you find out what applies to Currency forwards the particular derivative that you will be investing in. The purpose may be to hedge a future payment or receivable at a known How currency derivatives work foreign exchange rate, thus avoiding a currency risk Currency derivatives are used to hedge a future payment or receivable in A currency forward is an agreement between two parties, where both the a foreign currency or to change a currency exposure over time. -
Derivations Derivations
DERIVATIONS® DEMYSTIFYING RISK MANAGEMENT SOLUTIONS VOLUME NO. 20 REVISIONS TO ACCOUNTING THE CHALLENGE RULES REOPENS DOOR TO DERIVATIVES IN CROSS-BORDER The global nature of the capital markets allows many companies to capture lower costs of FINANCING funds and greater market liquidity by raising capital outside their country of domicile. However, the full benefits of cheaper funding can only be realized if there is an Recent revisions to the new U.S. deri- economically viable, and financial statement friendly, method to convert foreign currency vatives accounting rules make it possible cash flows back into the company's functional currency. for U.S. GAAP issuers to again use cross- Long-term cross-currency interest rate swaps are a proven technique for addressing this currency interest rate swaps in global problem. They allow financing to be raised in the most efficient market, carry over the funding strategies. The changes restore financing advantages (cost, covenants, and rate character) from the source to the target financial statement hedge treatment for a currency, and eliminate currency risk on a cash-flow-neutral basis. widely used tool that enables borrowers to New U.S. accounting rules for derivatives and hedging activity have changed the financial access low cost capital across the world. statement impact of cross-currency interest rate swaps. The rules require mark-to-market treatment for derivative contracts, unless certain stringent hedge accounting rules are met, in which case deferral accounting is allowed. As initially written, the new rules excluded almost all cross-currency swaps from meeting hedge accounting guidelines. However, recent revisions now permit appropriately constructed transactions to qualify for hedge accounting. -
Foreign Currency Swaps
RECORD OF SOCIETY OF ACTUARIES 1990 VOL. 16 NO. 2 FOREIGN CURRENCY SWAPS Moderator: RANDALL LEE BOUSHEK Panelists: JOSEPH C. LAU* MICHAEL B. MURDOCH** PATRICIA OWENS** * Recorder: RANDALL LEE BOUSHEK o With the globalization of the capital markets and more active entry of U.S. insurance companies into the international insurance market, this instrument may become more widely used. -- What is it? -- Past uses and results -- Future potential uses MR. RANDALL LEE BOUSHEK: This is the panel discussion on foreign currency swaps. My name is Randy Boushek and I will be the moderator for this session. I am what you might call a nontraditional actuary, involved in asset management at Lutheran Brotherhood, a $7 billion fraternal benefit society headquartered in Minneapolis. Within our operation I am responsible for directing investment in all derivative securities markets, including mortgage-backed securities, asset-backed securities, options, futures, swaps, index-linked notes and other esoteric securities. At Lutheran Brotherhood we, like many in the industry, have for some time been researching the currency swap and nondollar bond markets for investment opportunity. The reasons for this are twofold. First, on the asset side, nondollar denominated debt and equity securities now constitute the first and third largest securities markets in the world and cannot be ignored in the asset allocation decision. Second, on the liability side, the opening of international insurance markets and the potential for growth in nondollar insurance liabilities represents both a significant opportunity and a significant risk for the domestic insurance industry. As evidence of this potential, at present the U.S. consumer accounts for approximately 40% of the premiums collected in the world. -
Foreign Exchange Training Manual
CONFIDENTIAL TREATMENT REQUESTED BY BARCLAYS SOURCE: LEHMAN LIVE LEHMAN BROTHERS FOREIGN EXCHANGE TRAINING MANUAL Confidential Treatment Requested By Lehman Brothers Holdings, Inc. LBEX-LL 3356480 CONFIDENTIAL TREATMENT REQUESTED BY BARCLAYS SOURCE: LEHMAN LIVE TABLE OF CONTENTS CONTENTS ....................................................................................................................................... PAGE FOREIGN EXCHANGE SPOT: INTRODUCTION ...................................................................... 1 FXSPOT: AN INTRODUCTION TO FOREIGN EXCHANGE SPOT TRANSACTIONS ........... 2 INTRODUCTION ...................................................................................................................... 2 WJ-IAT IS AN OUTRIGHT? ..................................................................................................... 3 VALUE DATES ........................................................................................................................... 4 CREDIT AND SETTLEMENT RISKS .................................................................................. 6 EXCHANGE RATE QUOTATION TERMS ...................................................................... 7 RECIPROCAL QUOTATION TERMS (RATES) ............................................................. 10 EXCHANGE RATE MOVEMENTS ................................................................................... 11 SHORTCUT ............................................................................................................................... -
Using Financial Derivatives to Hedge Against Currency Risk
USING FINANCIAL DERIVATIVES TO HEDGE AGAINST CURRENCY RISK BRITISH LARGE AND MEDIUM-SIZE FIRMS MY NGUYEN Arcada University of Applied Sciences International Business 2012 DEGREE THESIS Arcada Degree Programme: International Business Identification number: 11680 Author: My Nguyen Title: Using financial derivatives to hedge against currency risk in British large and medium-sized firms Supervisor (Arcada): Andreas Stenius Commissioned by: Abstract: Nowadays, as a growing number of firms strive to conduct their business at international market place, currency risk has increasingly raised concern among financial mangers due to its substantial impact on companies’ financial results. Financial derivative instruments (Forward, Futures, Options, Swaps) are utilized as efficient hedging mechanisms against such an exchange rate exposure. The main objective of this study is to examine whether derivatives play a primary role in mitigating an adverse movement in currency in multinational firm. The research is carried out in British large and medium- sized companies. The empirical research was conducted on the basis of qualitative method. The findings reveal that the downward effect of currency risk is identified and evaluated in a majority of multinational companies. Although other hedging techniques such as netting, borrowings or natural hedge are at times employed, financial derivative instruments are crucial to hedge against currency risk in multinational companies. In general, forwards is designated as the most favorable type of derivates to minimize exchange rate fluctuation, followed by swaps. Furthermore, hedging strategy is implemented in accordance with individual firm’s policy. Keywords: Currency risk, financial derivatives, hedging, British companies , Sterling, Pound , Forward, Swap , Future, option Number of pages: Language: English Date of acceptance: Table of contents FOREWORD ...............................................................................................................