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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. -
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. -
Value at Risk for Linear and Non-Linear Derivatives
Value at Risk for Linear and Non-Linear Derivatives by Clemens U. Frei (Under the direction of John T. Scruggs) Abstract This paper examines the question whether standard parametric Value at Risk approaches, such as the delta-normal and the delta-gamma approach and their assumptions are appropriate for derivative positions such as forward and option contracts. The delta-normal and delta-gamma approaches are both methods based on a first-order or on a second-order Taylor series expansion. We will see that the delta-normal method is reliable for linear derivatives although it can lead to signif- icant approximation errors in the case of non-linearity. The delta-gamma method provides a better approximation because this method includes second order-effects. The main problem with delta-gamma methods is the estimation of the quantile of the profit and loss distribution. Empiric results by other authors suggest the use of a Cornish-Fisher expansion. The delta-gamma method when using a Cornish-Fisher expansion provides an approximation which is close to the results calculated by Monte Carlo Simulation methods but is computationally more efficient. Index words: Value at Risk, Variance-Covariance approach, Delta-Normal approach, Delta-Gamma approach, Market Risk, Derivatives, Taylor series expansion. Value at Risk for Linear and Non-Linear Derivatives by Clemens U. Frei Vordiplom, University of Bielefeld, Germany, 2000 A Thesis Submitted to the Graduate Faculty of The University of Georgia in Partial Fulfillment of the Requirements for the Degree Master of Arts Athens, Georgia 2003 °c 2003 Clemens U. Frei All Rights Reserved Value at Risk for Linear and Non-Linear Derivatives by Clemens U. -
Enns for Corporate and Sovereign CDS and FX Swaps
ENNs for Corporate and Sovereign CDS and FX Swaps by Lee Baker, Richard Haynes, Madison Lau, John Roberts, Rajiv Sharma, and Bruce Tuckman1 February, 2019 I. Introduction The sizes of swap markets, and the sizes of market participant footprints in swap markets, are most often measured in terms of notional amount. It is widely recognized, however, that notional amount is a poor metric of both size and footprint. First, when calculating notional amounts, the long and short positions between two counterparties are added together, even though longs and shorts essentially offset each other. Second, notional calculations add together positions with very different amounts of risk, like a relatively low-risk 3-month interest rate swap (IRS) and a relatively high-risk 30- year IRS. The use of notional amount to measure size distorts understanding of swap markets. A particularly powerful example arose around Lehman Brothers’ bankruptcy in September, 2008. At that time, there were $400 billion notional of outstanding credit default swaps (CDS) on Lehman, and Lehman’s debt was trading at 8.6 cents on the dollar. Many were frightened by the prospect that sellers of protection would soon have to pay buyers of protection a total of $400 billion x (1 – 8.6%), or about $365 billion. As it turned out, however, a large amount of protection sold had been offset by protection bought: in the end, protection sellers paid protection buyers between $6 and $8 billion.2 In January, 2018, the Office of the Chief Economist at the Commodity Futures Trading Commission (CFTC) introduced ENNs (Entity-Netted Notionals) as a metric of size in IRS markets.3 To compute IRS ENNs, all notional amounts are expressed in terms of the risk of a 5-year IRS, and long and short positions are netted when they are between the same pair of legal counterparties and denominated in the same currency. -
The Hedging Process
2016 Hedging What is hedging? Why would a business need it? How would it help mitigate risks? How would one be able to get started with it? How can MFX help? Everything it entails can be summarized in a concise, yet detailed step-by-step process. There are several key steps a company must follow in order to go through with this process and benefit. Let the simple flow chart below direct you as you read through this guide. Key Steps to the Hedging Process Why would you need hedging? Hedging using derivatives is a common and popular method for managing different kinds of risk for all different kinds of business. However, before going down the path of contracting a hedge, it is important to understand exactly what risk your institution faces. Without fully understanding how your financial position will react to changes in the risk factors you are trying to hedge, there is a risk that entering into a derivative contract could add additional risk of different kinds of risk than you currently face. It is important to think about other risk factors other than the one you are hedging that could affect the hedge. For example, how certain are you of the cash flows you are trying to hedge? Are you hedging balance sheet or cash risk? Are there natural hedges in other parts of your business that offset the risk you are trying to hedge? MFX’s team can help you consider the decision to hedge, but the client is responsible for assessing its risk and the appropriateness of hedging it. -
Forward and Futures Contracts
FIN-40008 FINANCIAL INSTRUMENTS SPRING 2008 Forward and Futures Contracts These notes explore forward and futures contracts, what they are and how they are used. We will learn how to price forward contracts by using arbitrage and replication arguments that are fundamental to derivative pricing. We shall also learn about the similarities and differences between forward and futures markets and the differences between forward and futures markets and prices. We shall also consider how forward and future prices are related to spot market prices. Keywords: Arbitrage, Replication, Hedging, Synthetic, Speculator, Forward Value, Maintainable Margin, Limit Order, Market Order, Stop Order, Back- wardation, Contango, Underlying, Derivative. Reading: You should read Hull chapters 1 (which covers option payoffs as well) and chapters 2 and 5. 1 Background From the 1970s financial markets became riskier with larger swings in interest rates and equity and commodity prices. In response to this increase in risk, financial institutions looked for new ways to reduce the risks they faced. The way found was the development of exchange traded derivative securities. Derivative securities are assets linked to the payments on some underlying security or index of securities. Many derivative securities had been traded over the counter for a long time but it was from this time that volume of trading activity in derivatives grew most rapidly. The most important types of derivatives are futures, options and swaps. An option gives the holder the right to buy or sell the underlying asset at a specified date for a pre-specified price. A future gives the holder the 1 2 FIN-40008 FINANCIAL INSTRUMENTS obligation to buy or sell the underlying asset at a specified date for a pre- specified price. -
Financial Derivatives Classification of Derivatives
FINANCIAL DERIVATIVES A derivative is a financial instrument or contract that derives its value from an underlying asset. The buyer agrees to purchase the asset on a specific date at a specific price. Derivatives are often used for commodities, such as oil, gasoline, or gold. Another asset class is currencies, often the U.S. dollar. There are derivatives based on stocks or bonds. The most common underlying assets include stocks, bonds, commodities, currencies, interest rates and market indexes. The contract's seller doesn't have to own the underlying asset. He can fulfill the contract by giving the buyer enough money to buy the asset at the prevailing price. He can also give the buyer another derivative contract that offsets the value of the first. This makes derivatives much easier to trade than the asset itself. According to the Securities Contract Regulation Act, 1956 the term ‘Derivative’ includes: i. a security derived from a debt instrument, share, loan, whether secured or unsecured, risk instrument or contract for differences or any other form of security. ii. a contract which derives its value from the prices or index of prices, of underlying securities. CLASSIFICATION OF DERIVATIVES Derivatives can be classified into broad categories depending upon the type of underlying asset, the nature of derivative contract or the trading of derivative contract. 1. Commodity derivative and Financial derivative In commodity derivatives, the underlying asset is a commodity, such as cotton, gold, copper, wheat, or spices. Commodity derivatives were originally designed to protect farmers from the risk of under- or overproduction of crops. Commodity derivatives are investment tools that allow investors to profit from certain commodities without possessing them. -
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. -
Derivative Instruments and Hedging Activities
www.pwc.com 2015 Derivative instruments and hedging activities www.pwc.com Derivative instruments and hedging activities 2013 Second edition, July 2015 Copyright © 2013-2015 PricewaterhouseCoopers LLP, a Delaware limited liability partnership. All rights reserved. PwC refers to the United States member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details. This publication has been prepared for general information on matters of interest only, and does not constitute professional advice on facts and circumstances specific to any person or entity. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication. The information contained in this material was not intended or written to be used, and cannot be used, for purposes of avoiding penalties or sanctions imposed by any government or other regulatory body. PricewaterhouseCoopers LLP, its members, employees and agents shall not be responsible for any loss sustained by any person or entity who relies on this publication. The content of this publication is based on information available as of March 31, 2013. Accordingly, certain aspects of this publication may be superseded as new guidance or interpretations emerge. Financial statement preparers and other users of this publication are therefore cautioned to stay abreast of and carefully evaluate subsequent authoritative and interpretative guidance that is issued. This publication has been updated to reflect new and updated authoritative and interpretative guidance since the 2012 edition. -
EQUITY DERIVATIVES Faqs
NATIONAL INSTITUTE OF SECURITIES MARKETS SCHOOL FOR SECURITIES EDUCATION EQUITY DERIVATIVES Frequently Asked Questions (FAQs) Authors: NISM PGDM 2019-21 Batch Students: Abhilash Rathod Akash Sherry Akhilesh Krishnan Devansh Sharma Jyotsna Gupta Malaya Mohapatra Prahlad Arora Rajesh Gouda Rujuta Tamhankar Shreya Iyer Shubham Gurtu Vansh Agarwal Faculty Guide: Ritesh Nandwani, Program Director, PGDM, NISM Table of Contents Sr. Question Topic Page No No. Numbers 1 Introduction to Derivatives 1-16 2 2 Understanding Futures & Forwards 17-42 9 3 Understanding Options 43-66 20 4 Option Properties 66-90 29 5 Options Pricing & Valuation 91-95 39 6 Derivatives Applications 96-125 44 7 Options Trading Strategies 126-271 53 8 Risks involved in Derivatives trading 272-282 86 Trading, Margin requirements & 9 283-329 90 Position Limits in India 10 Clearing & Settlement in India 330-345 105 Annexures : Key Statistics & Trends - 113 1 | P a g e I. INTRODUCTION TO DERIVATIVES 1. What are Derivatives? Ans. A Derivative is a financial instrument whose value is derived from the value of an underlying asset. The underlying asset can be equity shares or index, precious metals, commodities, currencies, interest rates etc. A derivative instrument does not have any independent value. Its value is always dependent on the underlying assets. Derivatives can be used either to minimize risk (hedging) or assume risk with the expectation of some positive pay-off or reward (speculation). 2. What are some common types of Derivatives? Ans. The following are some common types of derivatives: a) Forwards b) Futures c) Options d) Swaps 3. What is Forward? A forward is a contractual agreement between two parties to buy/sell an underlying asset at a future date for a particular price that is pre‐decided on the date of contract. -
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 ............................................................................................................................... -
Lecture 09: Multi-Period Model Fixed Income, Futures, Swaps
Fin 501:Asset Pricing I Lecture 09: Multi-period Model Fixed Income, Futures, Swaps Prof. Markus K. Brunnermeier Slide 09-1 Fin 501:Asset Pricing I Overview 1. Bond basics 2. Duration 3. Term structure of the real interest rate 4. Forwards and futures 1. Forwards versus futures prices 2. Currency futures 3. Commodity futures: backwardation and contango 5. Repos 6. Swaps Slide 09-2 Fin 501:Asset Pricing I Bond basics • Example: U.S. Treasury (Table 7.1) Bills (<1 year), no coupons, sell at discount Notes (1-10 years), Bonds (10-30 years), coupons, sell at par STRIPS: claim to a single coupon or principal, zero-coupon • Notation: rt (t1,t2): Interest rate from time t1 to t2 prevailing at time t. Pto(t1,t2): Price of a bond quoted at t= t0 to be purchased at t=t1 maturing at t= t2 Yield to maturity: Percentage increase in $s earned from the bond Slide 09-3 Fin 501:Asset Pricing I Bond basics (cont.) • Zero-coupon bonds make a single payment at maturity One year zero-coupon bond: P(0,1)=0.943396 • Pay $0.943396 today to receive $1 at t=1 • Yield to maturity (YTM) = 1/0.943396 - 1 = 0.06 = 6% = r (0,1) Two year zero-coupon bond: P(0,2)=0.881659 • YTM=1/0.881659 - 1=0.134225=(1+r(0,2))2=>r(0,2)=0.065=6.5% Slide 09-4 Fin 501:Asset Pricing I Bond basics (cont.) • Zero-coupon bond price that pays Ct at t: • Yield curve: Graph of annualized bond yields C against time P(0,t) t [1 r(0,t)]t • Implied forward rates Suppose current one-year rate r(0,1) and two-year rate r(0,2) Current forward rate from year 1 to year 2, r0(1,2), must satisfy: