Such positions generally are referred to in the financial markets as straddles
A taxpayer may elect to treat any gain or loss attributable to any foreign currency derivative that is not part of a straddle
(defined in IRC section 1092[c]) as capital gain or loss if the foreign currency derivative is a capital asset in the hands of the taxpayer (IRC section 988[a][B]).
2l) Future regulations may clarify the manner in which these rules may be applied to mixed straddles
can also be found in 3-word phrases if the second word is included in the straddle
: JUST A TICK (cpf), EAU DE NIL (Cham), THANKS A MILLION; and what the exchange rate has done--RISEN TEN CENTS (coined).
Someone comparing the implied volatility with the simple measure of historical volatility might often be tempted to sell straddles
The behavioral interactions involved one or both lizards exhibiting at least one of the following seven behaviors: supplant, trail, straddle
, chase, face-off, arched back display or straddle
-bite (Table 1).
GainsKeeper FundTaxPro applies both of the distinct loss deferral rules for straddles
and then tracks positions in future periods.
The IRS concluded in FSA 1999-664 that "substantial litigation hazards" existed with disallowing the taxpayer's prestraddle loss, and that the regulations did not preclude the taxpayer from establishing identified mixed straddles
with only those positions that would produce a capital loss.
Stock that is part of a straddle
at least one of the offsetting positions of which is a securities futures contract (see Q 1072) with respect to the stock or substantially identical stock will be subject to the straddle
Today, what's left of the Chicxulub crater, which is named for the fishing village near its center, straddles
the northwest coast of Mexico's Yucatan peninsula.
Previously, investors used straddles
to create immediate deductible tax losses without a current economic loss.
The book explains the mark-to-market rules, wash sales, short sales, straddles
and foreign-currency-dominated instruments.
National Bedding is buying 16 acres of land in the Kalkberg Commerce Park, which straddles
the towns of New Baltimore and Coxsackie.
These males still courted normally, luring a female to perform an amphibian waltz in which she straddles
his tail and the pair waddles forward.
Notices 2002-50, 2003-54 and 2002-65 straddle
tax shelters: These transactions use tiered passthough entities to claim deductions for noneconomic losses on foreign currency straddles