What are the prospects for the favorable settlement of pre-1982 straddle losses?

Article Abstract:

Straddles are futures contracts which involve the investor in both buy and sell positions, such that no economic gain or loss will be incurred form the contract, unless the spread changes. Straddles are entered into for one of two reasons: the conversion of a short-term capital gain to long-term capital gain for tax purposes, and the deferral of a taxable gain to a subsequent tax year (to reduce current taxes). The deductibility of tax losses incurred by corporations as a result of straddle contracts is discussed from the following perspectives: the Economic Recovery Tax Act of 1981, decisions made by various tax courts, and proposed legislation affecting tax straddles and accounting for taxes thereon.

Accounting and auditing, Capital gains tax, Commodity futures, Commodity swaps

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Deducting losses on the sale of a former personal residence

Article Abstract:

Losses on the sale of personal residence may be deductible, in full or in part, as business or investment losses if the residence has been transformed into rental or income-producing property before the sale. The characterization of the property determines the tax treatment of the loss. If the converted residence is considered a capital asset, Section 1211 sets the limit on the loss at $3,000 for each year, net of capital gains. On the other hand, if the residence is used in the taxpayer's trade or business, the loss will be treated as a deductible ordinary loss as required by Section 1231. Basis for loss on the converted property's disposition is subject to special regulations.

House selling, Home selling

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Net operating carryforward limits are described in new regulations

Article Abstract:

The IRS recently issued guidelines on the availability of net operating loss (NOL) carryforwards when a change of ownership occurs. The use of the NOL carryforward is either eliminated or severely restricted by a substantial change in ownership. The definition of ownership shifts under the new rules, and examples of how the laws are applied are provided.

Laws, regulations and rules, Tax accounting

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