The Resource A realization-based approach to the taxation of financial instruments

A realization-based approach to the taxation of financial instruments

Label
A realization-based approach to the taxation of financial instruments
Title
A realization-based approach to the taxation of financial instruments
Creator
Subject
Language
eng
Summary
After an introduction, this article sets out the basic concepts of realization and accrual and describes the concept of investment risk. Section III describes the phenomenon of carved-out interests in property, or "carve-outs", and demonstrates how the tax system should deal with them in light of the distinction between returns from investment risk and other kinds of returns. Carve-outs are common features of many financial instruments. Section IV then applies this analysis to two common financial instruments, showing that the investment risk criterion and the carve-out analysis permit taxation of these instruments in a way that is reasonably consistent with the politics that support realization-based taxation and that provides a high degree of consistency and continuity within the tax system. Section V draws several conclusions from the approach developed by the author
Citation source
In: Tax law review. - New York. - Vol. 57 (2004),
http://library.link/vocab/creatorName
Hasen, D.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • disposal
  • financial instrument
Label
A realization-based approach to the taxation of financial instruments
Instantiates
Publication
Label
A realization-based approach to the taxation of financial instruments
Publication

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      52.37366609999999 4.9336932
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