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
  • 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
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2004/T/TAXLARE/vol.57/3_397-481.zip
Publication
Note
20050114

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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