The Tenth Circuit, in Anschutz v. Commissioner, affirmed a Tax Court decision taxing the disposition of appreciated stock through a Variable Prepaid Forward Contract (VPFC). The underlying issue was whether the complex financial arrangement created a taxable constructive sale. The transaction involved a series of contracts including (1) a “forward contract” to sell the appreciated… Continue Reading
Category Archives: Securities
Subscribe to Securities RSS FeedCourt Rules Taxpayer Not a “Trader” – Losses Suspended
Posted in Deductions, SecuritiesIn a Tax Court Memorandum decision, the court denied a taxpayer’s “trader” status, suspending over $2 million in loss deductions from stock trades and imposing penalties. The court found that the taxpayer did not meet the definition of a “trader” who is engaged in the trade or business of selling securities for their own account…. Continue Reading
FAQs on Cost-Basis Reporting for Brokers
Posted in SecuritiesThe IRS published a list of Frequently Asked Questions on the new expanded tax reporting requirements for brokers which include reporting their customer’s tax basis and holding period information. The guidance explains the types of securities covered, how to report tax basis if less than all securities are sold, when returns are due, who qualifies… Continue Reading
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