W17(C) Appendix F
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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. - 
												
												Interest Rate Options
Interest Rate Options Saurav Sen April 2001 Contents 1. Caps and Floors 2 1.1. Defintions . 2 1.2. Plain Vanilla Caps . 2 1.2.1. Caplets . 3 1.2.2. Caps . 4 1.2.3. Bootstrapping the Forward Volatility Curve . 4 1.2.4. Caplet as a Put Option on a Zero-Coupon Bond . 5 1.2.5. Hedging Caps . 6 1.3. Floors . 7 1.3.1. Pricing and Hedging . 7 1.3.2. Put-Call Parity . 7 1.3.3. At-the-money (ATM) Caps and Floors . 7 1.4. Digital Caps . 8 1.4.1. Pricing . 8 1.4.2. Hedging . 8 1.5. Other Exotic Caps and Floors . 9 1.5.1. Knock-In Caps . 9 1.5.2. LIBOR Reset Caps . 9 1.5.3. Auto Caps . 9 1.5.4. Chooser Caps . 9 1.5.5. CMS Caps and Floors . 9 2. Swap Options 10 2.1. Swaps: A Brief Review of Essentials . 10 2.2. Swaptions . 11 2.2.1. Definitions . 11 2.2.2. Payoff Structure . 11 2.2.3. Pricing . 12 2.2.4. Put-Call Parity and Moneyness for Swaptions . 13 2.2.5. Hedging . 13 2.3. Constant Maturity Swaps . 13 2.3.1. Definition . 13 2.3.2. Pricing . 14 1 2.3.3. Approximate CMS Convexity Correction . 14 2.3.4. Pricing (continued) . 15 2.3.5. CMS Summary . 15 2.4. Other Swap Options . 16 2.4.1. LIBOR in Arrears Swaps . 16 2.4.2. Bermudan Swaptions . 16 2.4.3. Hybrid Structures . 17 Appendix: The Black Model 17 A.1. - 
												
												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. - 
												
												An Analysis of OTC Interest Rate Derivatives Transactions: Implications for Public Reporting
Federal Reserve Bank of New York Staff Reports An Analysis of OTC Interest Rate Derivatives Transactions: Implications for Public Reporting Michael Fleming John Jackson Ada Li Asani Sarkar Patricia Zobel Staff Report No. 557 March 2012 Revised October 2012 FRBNY Staff REPORTS This paper presents preliminary fi ndings and is being distributed to economists and other interested readers solely to stimulate discussion and elicit comments. The views expressed in this paper are those of the authors and are not necessarily refl ective of views at the Federal Reserve Bank of New York or the Federal Reserve System. Any errors or omissions are the responsibility of the authors. An Analysis of OTC Interest Rate Derivatives Transactions: Implications for Public Reporting Michael Fleming, John Jackson, Ada Li, Asani Sarkar, and Patricia Zobel Federal Reserve Bank of New York Staff Reports, no. 557 March 2012; revised October 2012 JEL classifi cation: G12, G13, G18 Abstract This paper examines the over-the-counter (OTC) interest rate derivatives (IRD) market in order to inform the design of post-trade price reporting. Our analysis uses a novel transaction-level data set to examine trading activity, the composition of market participants, levels of product standardization, and market-making behavior. We fi nd that trading activity in the IRD market is dispersed across a broad array of product types, currency denominations, and maturities, leading to more than 10,500 observed unique product combinations. While a select group of standard instruments trade with relative frequency and may provide timely and pertinent price information for market partici- pants, many other IRD instruments trade infrequently and with diverse contract terms, limiting the impact on price formation from the reporting of those transactions. - 
												
												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). - 
												
												Panagora Global Diversified Risk Portfolio General Information Portfolio Allocation
March 31, 2021 PanAgora Global Diversified Risk Portfolio General Information Portfolio Allocation Inception Date April 15, 2014 Total Assets $254 Million (as of 3/31/2021) Adviser Brighthouse Investment Advisers, LLC SubAdviser PanAgora Asset Management, Inc. Portfolio Managers Bryan Belton, CFA, Director, Multi Asset Edward Qian, Ph.D., CFA, Chief Investment Officer and Head of Multi Asset Research Jonathon Beaulieu, CFA Investment Strategy The PanAgora Global Diversified Risk Portfolio investment philosophy is centered on the belief that risk diversification is the key to generating better risk-adjusted returns and avoiding risk concentration within a portfolio is the best way to achieve true diversification. They look to accomplish this by evaluating risk across and within asset classes using proprietary risk assessment and management techniques, including an approach to active risk management called Dynamic Risk Allocation. The portfolio targets a risk allocation of 40% equities, 40% fixed income and 20% inflation protection. Portfolio Statistics Portfolio Composition 1 Yr 3 Yr Inception 1.88 0.62 Sharpe Ratio 0.6 Positioning as of Positioning as of 0.83 0.75 Beta* 0.78 December 31, 2020 March 31, 2021 Correlation* 0.87 0.86 0.79 42.4% 10.04 10.6 Global Equity 43.4% Std. Deviation 9.15 24.9% U.S. Stocks 23.6% Weighted Portfolio Duration (Month End) 9.0% 8.03 Developed non-U.S. Stocks 9.8% 8.5% *Statistic is measured against the Dow Jones Moderate Index Emerging Markets Equity 10.0% 106.8% Portfolio Benchmark: Nominal Fixed Income 142.6% 42.0% The Dow Jones Moderate Index is a composite index with U.S. - 
												
												Interest Rate Swap Contracts the Company Has Two Interest Rate Swap Contracts That Hedge the Base Interest Rate Risk on Its Two Term Loans
$400.0 million. However, the $100.0 million expansion feature may or may not be available to the Company depending upon prevailing credit market conditions. To date the Company has not sought to borrow under the expansion feature. Borrowings under the Credit Agreement carry interest rates that are either prime-based or Libor-based. Interest rates under these borrowings include a base rate plus a margin between 0.00% and 0.75% on Prime-based borrowings and between 0.625% and 1.75% on Libor-based borrowings. Generally, the Company’s borrowings are Libor-based. The revolving loans may be borrowed, repaid and reborrowed until January 31, 2012, at which time all amounts borrowed must be repaid. The revolver borrowing capacity is reduced for both amounts outstanding under the revolver and for letters of credit. The original term loan will be repaid in 18 consecutive quarterly installments which commenced on September 30, 2007, with the final payment due on January 31, 2012, and may be prepaid at any time without penalty or premium at the option of the Company. The 2008 term loan is co-terminus with the original 2007 term loan under the Credit Agreement and will be repaid in 16 consecutive quarterly installments which commenced June 30, 2008, plus a final payment due on January 31, 2012, and may be prepaid at any time without penalty or premium at the option of Gartner. The Credit Agreement contains certain customary restrictive loan covenants, including, among others, financial covenants requiring a maximum leverage ratio, a minimum fixed charge coverage ratio, and a minimum annualized contract value ratio and covenants limiting Gartner’s ability to incur indebtedness, grant liens, make acquisitions, be acquired, dispose of assets, pay dividends, repurchase stock, make capital expenditures, and make investments. - 
												
												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 .................................................................................................................................................................................................................... - 
												
												Form 6781 Contracts and Straddles ▶ Go to for the Latest Information
Gains and Losses From Section 1256 OMB No. 1545-0644 Form 6781 Contracts and Straddles ▶ Go to www.irs.gov/Form6781 for the latest information. 2020 Department of the Treasury Attachment Internal Revenue Service ▶ Attach to your tax return. Sequence No. 82 Name(s) shown on tax return Identifying number Check all applicable boxes. A Mixed straddle election C Mixed straddle account election See instructions. B Straddle-by-straddle identification election D Net section 1256 contracts loss election Part I Section 1256 Contracts Marked to Market (a) Identification of account (b) (Loss) (c) Gain 1 2 Add the amounts on line 1 in columns (b) and (c) . 2 ( ) 3 Net gain or (loss). Combine line 2, columns (b) and (c) . 3 4 Form 1099-B adjustments. See instructions and attach statement . 4 5 Combine lines 3 and 4 . 5 Note: If line 5 shows a net gain, skip line 6 and enter the gain on line 7. Partnerships and S corporations, see instructions. 6 If you have a net section 1256 contracts loss and checked box D above, enter the amount of loss to be carried back. Enter the loss as a positive number. If you didn’t check box D, enter -0- . 6 7 Combine lines 5 and 6 . 7 8 Short-term capital gain or (loss). Multiply line 7 by 40% (0.40). Enter here and include on line 4 of Schedule D or on Form 8949. See instructions . 8 9 Long-term capital gain or (loss). Multiply line 7 by 60% (0.60). Enter here and include on line 11 of Schedule D or on Form 8949. - 
												
												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. - 
												
												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.