The Resource A risk-based analysis of credit derivatives under the U.S. SSRP standard (part 1)

A risk-based analysis of credit derivatives under the U.S. SSRP standard (part 1)

Label
A risk-based analysis of credit derivatives under the U.S. SSRP standard (part 1)
Title
A risk-based analysis of credit derivatives under the U.S. SSRP standard (part 1)
Creator
Subject
Language
eng
Summary
This three-part special report addresses how the "substantially similar or related property" (SSRP) concept applies to credit derivatives and structured credit products under new section 901(l). This first installment examines the risk profile of fixed-income instruments in the light of the legislative history of section 901(l). It argues that the definition of a position in SSRP should be the same for all code sections employing the term. Under this analysis, the directive in the legislative history of section 901(l) that hedging interest rate and foreign currency risks do not toll the holding period should apply to all code sections using the SSRP concept. It also discusses how some of the directives in the legislative history about excusing certain hedges from the SSRP calculation require implementing regulations
Citation source
In: Tax notes international. - Arlington. - Vol. 44 (2006),
http://library.link/vocab/creatorName
Bogos, N
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • credit derivative
  • foreign tax credit
  • fixed income
Label
A risk-based analysis of credit derivatives under the U.S. SSRP standard (part 1)
Instantiates
Publication
Label
A risk-based analysis of credit derivatives under the U.S. SSRP standard (part 1)
Publication

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