Tag Archives: investors

No Action Relief Regarding Variation Margin Rules

Yesterday, the U.S. Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediary Oversight (DSIO) announced the issuance of a time-limited no-action letter stating that, from March 1, 2017 to September 1, 2017, DSIO will not recommend an enforcement action against a swap dealer (SD) for failure to comply with the variation margin requirements … Continue Reading

Massachusetts Offers Policy Guidance on Investment Advisers’ Use of Robo-Advisers

As robo-advisers continue to grow in popularity with investors, especially millennial investors, at least one regulator is taking a closer look.  On July 14, 2016, Massachusetts Secretary of the Commonwealth William Galvin issued a policy statement addressing the use by investment advisers under his jurisdiction of third-party robo-advisers.  This follows a similar policy statement by … Continue Reading

New New Guidance Regarding Barrier Options

In a recently released Chief Counsel Advice Memorandum (the CCA), the Internal Revenue Service broadened its scrutiny of so-called “barrier option” transactions, which taxpayers have used to defer recognition of income and to convert ordinary income and short-term capital gain to long-term capital gain.1  The government had previously announced that it would scrutinize these transactions … Continue Reading

‘Harvest’ Built-in Losses to Offset Capital Gains – The Trade Rule

As fund managers, insurance companies, and individual investors re-balance their portfolio at the end of the year, they often try to “harvest” built-in losses to offset capital gains. This implicates what tax lawyers call “the trade date rule.” With a few exceptions, the current income tax system has annual accounting periods, loss offsets, and a realization requirement. This … Continue Reading
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