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mark-to-market rules

Court of Appeals: over-the-counter foreign currency options were Code Sec. 1256 contracts

Court of Appeals: over-the-counter foreign currency options were Code Sec. 1256 contracts

Wright v. Comm., (CA 6 1/7/2016) 117 AFTR 2d ¶ 2016-319 The Court of Appeals for the Sixth Circuit, reversing the Tax Court, has held that over-the-counter foreign currency options entered into by a taxpayer qualified as Code Sec. 1256 foreign currency contracts. Accordingly, the mark-to-market rules applied, allowing the taxpayer to claim a significant […]

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Tax Court – Taxpayer didn’t make mark-to-market election, and Asperger’s didn’t excuse late filing

Tax Court – Taxpayer didn’t make mark-to-market election, and Asperger’s didn’t excuse late filing

Poppe, TC Memo 2015-205 The Tax Court has held that a taxpayer who traded extensively in his own account was engaged in a trade or business as a trader, that he failed to properly elect the mark-to-market accounting method, and that his having organizational difficulties due to autistic spectrum disorder (ASD, formerly known as Asperger’s […]

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IRS extends date on embedded loan rule for nonperiodic payments

IRS extends date on embedded loan rule for nonperiodic payments

T.D. 9719, 10/09/2015, Reg. § 1.446-3T IRS has amended the recently issued temporary regs under Code Sec. 446 on nonperiodic payments made or received pursuant to certain notional principal contracts (NPCs) to extend the applicability date of the embedded loan rule for the treatment of nonperiodic payments from Nov. 4, 2015, to the later of Jan. 1, […]

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Application of mark-to-market rules to transactions taxpayer treated as options

Application of mark-to-market rules to transactions taxpayer treated as options

Chief Counsel Advice 201432016 In Chief Counsel Advice, IRS has provided various theories that IRS auditors could use to argue against a securities trader who claimed that a somewhat complicated transaction that it entered into regularly created an option. Each of the arguments involved the fact that the trader had made the mark-to-market election with […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney