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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. -
Faqs on Straddle Contracts – Currency Derivatives
FAQs on Straddle Contracts FAQs on Straddle Contracts – Currency Derivatives 1. What is meant by a Straddle Contract? Straddle contracts are specialised two-legged option contracts that allow a trader to take positions on two different option contracts belonging to the same product, at the same strike price and having the same expiry. 2. What are the components of a Straddle contract? A straddle contract comprises of two individual legs, the first being the call option leg and the second being the put option leg, having same strike price and expiry. 3. In which segment will Straddle contracts be offered? To start with, straddle contracts will be offered in the Currency Derivatives segment. 4. What will be the market lot of the straddle contract? Market lot of a straddle contract will be the same as that of its corresponding individual legs i.e. the market lot of the call option leg and the put option leg. 5. What will be the tick size of the straddle contract? Tick size of a straddle contract will be the same as that of its corresponding individual legs i.e. the tick size of the call option leg and the put option leg. 6. For which expiries will straddle contracts be made available? Straddle contracts will be made available on all existing individual option contracts - current, near, & far monthly as well as quarterly and half yearly option contracts. 7. How many in-the-money, at-the-money and out-of-the-money contracts will be available? Minimum two In-the-Money, two Out-of-the-Money and one At-the-Money straddle contracts will be made available. -
Buying Options on Futures Contracts. a Guide to Uses
NATIONAL FUTURES ASSOCIATION Buying Options on Futures Contracts A Guide to Uses and Risks Table of Contents 4 Introduction 6 Part One: The Vocabulary of Options Trading 10 Part Two: The Arithmetic of Option Premiums 10 Intrinsic Value 10 Time Value 12 Part Three: The Mechanics of Buying and Writing Options 12 Commission Charges 13 Leverage 13 The First Step: Calculate the Break-Even Price 15 Factors Affecting the Choice of an Option 18 After You Buy an Option: What Then? 21 Who Writes Options and Why 22 Risk Caution 23 Part Four: A Pre-Investment Checklist 25 NFA Information and Resources Buying Options on Futures Contracts: A Guide to Uses and Risks National Futures Association is a Congressionally authorized self- regulatory organization of the United States futures industry. Its mission is to provide innovative regulatory pro- grams and services that ensure futures industry integrity, protect market par- ticipants and help NFA Members meet their regulatory responsibilities. This booklet has been prepared as a part of NFA’s continuing public educa- tion efforts to provide information about the futures industry to potential investors. Disclaimer: This brochure only discusses the most common type of commodity options traded in the U.S.—options on futures contracts traded on a regulated exchange and exercisable at any time before they expire. If you are considering trading options on the underlying commodity itself or options that can only be exercised at or near their expiration date, ask your broker for more information. 3 Introduction Although futures contracts have been traded on U.S. exchanges since 1865, options on futures contracts were not introduced until 1982. -
Jazz and the Cultural Transformation of America in the 1920S
Louisiana State University LSU Digital Commons LSU Doctoral Dissertations Graduate School 2003 Jazz and the cultural transformation of America in the 1920s Courtney Patterson Carney Louisiana State University and Agricultural and Mechanical College, [email protected] Follow this and additional works at: https://digitalcommons.lsu.edu/gradschool_dissertations Part of the History Commons Recommended Citation Carney, Courtney Patterson, "Jazz and the cultural transformation of America in the 1920s" (2003). LSU Doctoral Dissertations. 176. https://digitalcommons.lsu.edu/gradschool_dissertations/176 This Dissertation is brought to you for free and open access by the Graduate School at LSU Digital Commons. It has been accepted for inclusion in LSU Doctoral Dissertations by an authorized graduate school editor of LSU Digital Commons. For more information, please [email protected]. JAZZ AND THE CULTURAL TRANSFORMATION OF AMERICA IN THE 1920S A Dissertation Submitted to the Graduate Faculty of the Louisiana State University and Agricultural and Mechanical College in partial fulfillment of the requirements for the degree of Doctor of Philosophy in The Department of History by Courtney Patterson Carney B.A., Baylor University, 1996 M.A., Louisiana State University, 1998 December 2003 For Big ii ACKNOWLEDGEMENTS The real truth about it is no one gets it right The real truth about it is we’re all supposed to try1 Over the course of the last few years I have been in contact with a long list of people, many of whom have had some impact on this dissertation. At the University of Chicago, Deborah Gillaspie and Ray Gadke helped immensely by guiding me through the Chicago Jazz Archive. -
307439 Ferdig Master Thesis
Master's Thesis Using Derivatives And Structured Products To Enhance Investment Performance In A Low-Yielding Environment - COPENHAGEN BUSINESS SCHOOL - MSc Finance And Investments Maria Gjelsvik Berg P˚al-AndreasIversen Supervisor: Søren Plesner Date Of Submission: 28.04.2017 Characters (Ink. Space): 189.349 Pages: 114 ABSTRACT This paper provides an investigation of retail investors' possibility to enhance their investment performance in a low-yielding environment by using derivatives. The current low-yielding financial market makes safe investments in traditional vehicles, such as money market funds and safe bonds, close to zero- or even negative-yielding. Some retail investors are therefore in need of alternative investment vehicles that can enhance their performance. By conducting Monte Carlo simulations and difference in mean testing, we test for enhancement in performance for investors using option strategies, relative to investors investing in the S&P 500 index. This paper contributes to previous papers by emphasizing the downside risk and asymmetry in return distributions to a larger extent. We find several option strategies to outperform the benchmark, implying that performance enhancement is achievable by trading derivatives. The result is however strongly dependent on the investors' ability to choose the right option strategy, both in terms of correctly anticipated market movements and the net premium received or paid to enter the strategy. 1 Contents Chapter 1 - Introduction4 Problem Statement................................6 Methodology...................................7 Limitations....................................7 Literature Review.................................8 Structure..................................... 12 Chapter 2 - Theory 14 Low-Yielding Environment............................ 14 How Are People Affected By A Low-Yield Environment?........ 16 Low-Yield Environment's Impact On The Stock Market........ -
Tax Treatment of Derivatives
United States Viva Hammer* Tax Treatment of Derivatives 1. Introduction instruments, as well as principles of general applicability. Often, the nature of the derivative instrument will dictate The US federal income taxation of derivative instruments whether it is taxed as a capital asset or an ordinary asset is determined under numerous tax rules set forth in the US (see discussion of section 1256 contracts, below). In other tax code, the regulations thereunder (and supplemented instances, the nature of the taxpayer will dictate whether it by various forms of published and unpublished guidance is taxed as a capital asset or an ordinary asset (see discus- from the US tax authorities and by the case law).1 These tax sion of dealers versus traders, below). rules dictate the US federal income taxation of derivative instruments without regard to applicable accounting rules. Generally, the starting point will be to determine whether the instrument is a “capital asset” or an “ordinary asset” The tax rules applicable to derivative instruments have in the hands of the taxpayer. Section 1221 defines “capital developed over time in piecemeal fashion. There are no assets” by exclusion – unless an asset falls within one of general principles governing the taxation of derivatives eight enumerated exceptions, it is viewed as a capital asset. in the United States. Every transaction must be examined Exceptions to capital asset treatment relevant to taxpayers in light of these piecemeal rules. Key considerations for transacting in derivative instruments include the excep- issuers and holders of derivative instruments under US tions for (1) hedging transactions3 and (2) “commodities tax principles will include the character of income, gain, derivative financial instruments” held by a “commodities loss and deduction related to the instrument (ordinary derivatives dealer”.4 vs. -
US Options FIX Specification
US Options FIX Specification Version 2.7.37 September 9, 2021 This content is owned or licensed by Cboe Global Markets, Inc. or its affiliates (“Cboe”) and protected by copyright under U.S. and international copyright laws. Other than for internal business purposes, you may not copy, reproduce, distribute, publish, display, perform, modify, create derivative works, transmit, or in any way exploit the content, sell or offer it for sale, use the content to construct any kind of database, or alter or remove any copyright or other notice from copies of the content. Cboe US Options FIX Specification (Version 2.7.37) Contents 1 Introduction.......................................................................................................................... 5 1.1 Overview .............................................................................................................................................. 5 1.2 Document Format ............................................................................................................................... 5 1.3 Hours of Operation .............................................................................................................................. 5 Holiday Sessions (C1 only) (Effective 11/21/21) ............................................................................. 6 1.4 Data Types ........................................................................................................................................... 6 Times .............................................................................................................................................. -
Updated Trading Participants' Trading Manual
Annexure 3 TRADING MANUAL BURSA MALAYSIA DERIVATIVES BHD TRADING MANUAL (Version 4.10) This manual is the intellectual property of BURSA MALAYSIA. No part of the manual is to be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording or any information storage and retrieval system, without permission in writing from Head of BMD Exchange Operations. TRADING MANUAL Version History Version Date Author Comments V 1.0 9 Aug 2010 BMDB Initial Version V 1.1 27 Aug 2010 BMDB Updated # 6.6.3 Review of Trades – Price Adjustments and Cancellations V1.2 6 Sep 2010 BMDB Inserted 15. Operator ID (“Tag 50 ID”) Required for All BMD orders traded on CME Globex V1.3 9 Sep 2010 BMDB Update 1. Introduction – 1.6 TPs’ compliance in relation to access, connectivity, specification or use of CME Globex V1.4 13 Sep 2010 BMDB Updated 13. Messaging And Market Performance Protection Policy V1.5 9 Nov 2011 BMDB Inserted 16 Negotiated Large Trade V1.6 18 Nov 2011 BMDB Amended section 16 for typo errors, consistency and clarity. V1.7 24 Nov 2011 BMDB Amended section 16 - Extended NLT cut-off time for FKLI, FKB3 and FMG5 to 4.00pm and for FCPO to 5.00pm. -Amended the NLT Facility Trade Registration form. V1.8 10 Feb 2012 BMDB Updated section 11 EFP to EFRP V1.9 23 Mar 2012 BMDB Amended sections 11 and 16 (forms and processes) V2.0 5 Apr 2012 BMDB Renamed to “Trading Manual” V2.1 14 May 2012 BMDB Updated Section 6 for OKLI and to align with CME practice V2.2 29 May 2012 BMDB i) Updated for OCPO ii) Change of terminology to be consistent with CME iii) Updated Sections 7.7 & 14.1 for consistency with Rules iv) Updated Sections 12.3 & 12.4 for accuracy v) Updated Section 3.1 on options naming convention V2.3 18 Feb 2013 BMDB Updated Section 16 NLT V2.4 3 Apr 2013 BMDB Updated Section 9 Circuit Breaker on timing V2.5 2 Jul 2013 BMDB Updated FGLD. -
November 4, 2016 Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk
November 4, 2016 Ms. Susan M. Cosper Technical Director Financial Accounting Standards Board 401 Merritt 7 P.O. Box 5116 Norwalk, CT 06856-5116 By email: [email protected] Re: File Reference Number 2016-310, Exposure Draft, Derivatives and Hedging (Topic 815) – Targeted Improvements to Accounting for Hedging Activities Dear Ms. Cosper, The International Swaps and Derivatives Association’s (ISDA)1 Accounting Policy Committee appreciates the opportunity to comment on the Financial Accounting Standards Board’s (“FASB”) Exposure Draft, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging Activities (the “Exposure Draft”). Collectively, the Committee members have substantial professional expertise and practical experience addressing accounting policy issues related to financial instruments and specifically derivative financial instruments. This letter provides our organization’s overall views on the Exposure Draft and our responses to the questions for respondents included within the Exposure Draft. Overview ISDA supports the FASB’s efforts to simplify the accounting for hedging activities and address practice issues that have arisen under current generally accepted accounting principles (“GAAP”). We believe the Exposure Draft achieves the FASB’s objectives of improving the financial reporting of cash flow and fair value hedge relationships to better portray the economic results of an entity’s risk management activities in its financial statements and simplifying the application of hedge accounting guidance in current GAAP. 1 Since 1985, the International Swaps and Derivatives Association has worked to make the global derivatives markets safer and more efficient. ISDA’s pioneering work in developing the ISDA Master Agreement and a wide range of related documentation materials, and in ensuring the enforceability of their netting and collateral provisions, has helped to significantly reduce credit and legal risk. -
Options in Asset Allocation Problems: an Empirical Model Applied to the Italian FTSE MIB Index
Dipartimento di Impresa e Management Cattedra Asset Pricing Options in asset allocation problems: an empirical model applied to the Italian FTSE MIB Index Prof. Paolo Porchia Prof. Marco Pirra RELATORE CORRELATORE Matr. 705881 CANDIDATO Anno Accademico 2019/2020 1 2 Contents Introduction...................................................................................................................................................... 4 1). What are options? History, definitions, and strategies. .......................................................................... 6 1.1). Options: brief history and general definition. ....................................................................................... 6 1.2). Plain Vanilla and Exotic options: main determinants, greeks, payoffs. .............................................. 11 1.3) The most common options strategies. .................................................................................................. 21 2). The role of options in investors’ portfolios. ........................................................................................... 30 2.1). The role of options in buy and hold portfolios to solve the classic asset allocation problem. ............ 30 2.2). Benefit from including derivatives in optimal dynamic strategies. ..................................................... 37 2.3). Optimal Portfolio’s choices whit jumps in volatility. ......................................................................... 43 2.4). A myopic portfolio to exploit the mispricing. -
Introduction to Options Mark Welch and James Mintert*
E-499 RM2-2.0 01-09 Risk Management Introduction To Options Mark Welch and James Mintert* Options give the agricultural industry a flexi- a put option can convert an option position into ble pricing tool that helps with price risk manage- a short futures position, established at the strike ment. Options offer a type of insurance against price, by exercising the put option. Similarly, the adverse price moves, require no margin deposits buyer of a call option can convert an option posi- for buyers, and allow buyers to participate in tion into a long futures position, established at favorable price moves. Commodity options are the strike price, by exercising the call option. The adaptable to a wide range of pricing situations. option buyer also can sell the option to someone For example, agricultural producers can use com- else or do nothing and let the option expire. The modity options to establish an approximate price choice of action is left entirely to the option buyer. floor, or ceiling, for their production or inputs. The option buyer obtains this right by paying the With today’s large price fluctuations, the financial premium to the option seller. payoff in controlling price risk and protecting What about the option seller? The option seller profits can be substantial. receives the premium from the option buyer. If the option buyer exercises the option, the option What is an Option? seller is obligated to take the opposite futures An option is simply the right, but not the position at the same strike price. Because of the obligation, to buy or sell a futures contract at seller’s obligation to take a futures position if the some predetermined price within a specified option is exercised, an option seller must post a time period. -
The Pricing of Stock Index Futures During the Asian Financial Crisis: Evidence from Four Asian Index Futures Markets”
“The Pricing of Stock Index Futures During the Asian Financial Crisis: Evidence from Four Asian Index Futures Markets” AUTHORS Janchung Wang Janchung Wang (2007). The Pricing of Stock Index Futures During the Asian ARTICLE INFO Financial Crisis: Evidence from Four Asian Index Futures Markets. Investment Management and Financial Innovations, 4(2) RELEASED ON Saturday, 23 June 2007 JOURNAL "Investment Management and Financial Innovations" FOUNDER LLC “Consulting Publishing Company “Business Perspectives” NUMBER OF REFERENCES NUMBER OF FIGURES NUMBER OF TABLES 0 0 0 © The author(s) 2021. This publication is an open access article. businessperspectives.org Investment Management and Financial Innovations, Volume 4, Issue 2, 2007 77 THE PRICING OF STOCK INDEX FUTURES DURING THE ASIAN FINANCIAL CRISIS: EVIDENCE FROM FOUR ASIAN INDEX FUTURES MARKETS Janchung Wang* Abstract Market imperfections are traditionally measured individually. Hsu and Wang (2004) and Wang and Hsu (2006) recently proposed the concept of the degree of market imperfections, which reflects the total effects of all market imperfections between the stock index futures market and its underlying index market when implementing arbitrage activities. This study discusses some useful applications of this concept. Furthermore, Hsu and Wang (2004) developed an imperfect market model for pricing stock index futures. This study further compares the relative pricing perform- ance of the cost of carry and the imperfect market models for four Asian index futures markets (particularly for the Asian crisis period). The evidence indicates that market imperfections are im- portant in determining the stock index futures prices for immature markets and turbulent periods with high market imperfections. Nevertheless, market imperfections are excluded from the cost of carry model.