Derivatives based on US estate

Journal
Carman, P.D.
United States
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2009 (Volume 11), No. 3
PriceUSD 45

A recent ruling by the US Internal Revenue Service may raise issues about whether derivatives based upon narrow indexes related to US real property will be taxed as interests in US real property. The result of such characterization would be US taxation of gains without regard to available treaty protection.