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Straddles

Taxpayer’s Issuance of Debt Exchangeable For Stock It Owned Created a Straddle

Taxpayer’s Issuance of Debt Exchangeable For Stock It Owned Created a Straddle

Legal Advice Issued by Field Attorneys 20151201F In Legal Advice issued by Field Attorneys, IRS has concluded that: a) a taxpayer’s issuance of bonds that were exchangeable for shares of public companies that were owned by the taxpayer at the time of the bond issuance, created a straddle; and b) as a result, the taxpayer […]

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Final regs adopt modified gain recognition rules for new identified mixed straddles

Final regs adopt modified gain recognition rules for new identified mixed straddles

T.D. 9678, 07/17/2014; Reg. § 1.1092-3T; Reg. § 1.1092(b)-6 IRS has issued final regs that relate to new Code Sec. 1092 identified mixed straddles established after Aug. 17, 2014. In general, the final regs adopt temporary regs that were issued last summer, with a few modifications. The final regs explain how to account for unrealized […]

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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