US Taxation of Foreign Currency Derivatives: 30 Years of Uncertainty

Journal
Hammer, V.
United States
Bulletin for International Taxation 2010 (Volume 64), No. 3
PriceUSD 45

Foreign currency contracts were required to be marked to market in the United States in 1982, but since then practitioners have argued about the scope of the rule. Specifically, does the rule apply to foreign currency forwards only or to options, swaps and other derivatives as well?