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Internal Revenue Code (IRC) Foreign Currency Investment

ASKramer Law

Taxation of Foreign Currency Transactions Part I: Definitions and Rules for Taxing Foreign Currencies

ASKramer Law on

Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more

Cadwalader, Wickersham & Taft LLP

Looking Forward: The IRS Denies 40/60 Treatment for Over-the-Counter Foreign Currency Options under the Mark-to-Market Rules

The IRS has published Proposed Regulations clarifying that for purposes of the mark-to-market rules under section 1256, foreign currency contracts include only foreign currency forward contracts, and that the definition does...more

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