| Volume 1 |
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| Abbreviations |
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xix | |
| PART ONE OVERVIEW OF THE MARKETS |
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Overview of the U.S. Corporate Equity and Debt Securities Markets |
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1 | (1) |
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Overview of the U.S. Government Securities Markets |
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2 | (1) |
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Overview of the U.S. Municipal Securities Markets |
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3 | (1) |
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Overview of U.S. Commodities Trading and Regulation |
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4 | (1) |
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Overview of the U.S. Options Markets |
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5 | (1) |
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Overview of the U.S. Over-the-Counter Derivatives Markets |
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6 | (1) |
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Overview of the U.S. Asset-Backed Securities Market |
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7 | (1) |
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Overview of the Foreign Exchange Markets in the United States |
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8 | (1) |
| PART TWO OVERVIEW OF SELECTED MARKET PARTICIPANTS |
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Regulated Investment Companies |
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9 | (1) |
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Real Estate Investment Trusts |
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10 | (1) |
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Real Estate Mortgage Investment Conduits |
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11 | (1) |
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Financial Asset Securitization Investment Trusts |
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12 | (1) |
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Partnerships, Hedge Funds, and Pooled Investments |
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13 | (1) |
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14 | (1) |
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Insurance Company Use of Derivatives |
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15 | (1) |
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Energy Company Use of Derivatives |
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16 | (1) |
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17 | (1) |
| Volume 2 |
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| Abbreviations |
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iii | |
| PART THREE TAXATION OF MARKET PARTICIPANTS |
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Overview of Market Participants |
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18 | (1) |
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19 | (1) |
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20 | (1) |
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21 | (1) |
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22 | (1) |
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23 | (1) |
| PART FOUR TAXATION OF CAPITAL TRANSACTIONS |
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General Principles of Capital Assets |
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24 | (1) |
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Computation of Gains or Losses |
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25 | (1) |
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26 | (1) |
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27 | (1) |
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Short Sales of Capital Assets |
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28 | (1) |
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Wash Sales of Stock or Securities |
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29 | (1) |
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Identification of Capital Assets |
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30 | (1) |
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31 | (1) |
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32 | (1) |
| PART FIVE TAXATION OF ORDINARY INCOME TRANSACTIONS |
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General Principles of Ordinary Income Transactions |
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33 | (1) |
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Identification of Ordinary Income Property |
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34 | (1) |
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35 | (1) |
| PART SIX PROFIT MOTIVE, SHAM, BUSINESS PURPOSE, AND OTHER ANTI-ABUSE CONSIDERATIONS |
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Anti-Abuse Considerations |
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36 | (1) |
| PART SEVEN TREATMENT OF GAIN OR LOSS ON TERMINATIONS OF CONTRACT RIGHTS AND OBLIGATIONS |
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Terminations of Contract Rights and Obligations |
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37 | (1) |
| PART EIGHT TAXATION OF DIVIDEND INCOME, INTEREST INCOME, SECURITY LOANS, AND REPURCHASE TRANSACTIONS |
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38 | (1) |
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39 | (1) |
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40 | (1) |
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Repurchase Transactions and Reverse Repurchase Transactions |
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41 | (1) |
| PART NINE TAXATION OF STOCK AND OTHER EQUITY SECURITIES, OPTIONS ON SECURITIES, PUBLICLY TRADED PARTNERSHIP INTERESTS, AND PUBLICLY TRADED TRUST INTERESTS |
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Stock and Equity Securities |
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42 | (1) |
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Partnership and Limited Liability Company Interests |
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43 | (1) |
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Publicly Traded Trust Interests |
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44 | (1) |
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Options on Stock and Stock Indices |
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45 | (1) |
| Volume 3 |
|
| Abbreviations |
|
iii | |
| PART TEN TAXATION OF DEBT SECURITIES AND OPTIONS ON DEBT SECURITIES |
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General Principles for Taxation of Debt Securities |
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46 | (1) |
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47 | (1) |
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48 | (1) |
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Convertible Debt Securities |
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49 | (1) |
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Contingent Debt Securities |
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50 | (1) |
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51 | (1) |
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Options on Debt Securities |
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52 | (1) |
| PART ELEVEN TAXATION OF ASSET-BACKED SECURITIES |
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Tax Considerations for Entities Used to Pool Asset-Backed Securities |
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53 | (1) |
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Taxation of Pass-Through Certificate Owners |
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54 | (1) |
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Taxation of Pay-Through Bond Owners |
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55 | (1) |
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Taxation of Owners of Equity Interests in Entities Issuing Pay-Through Bonds |
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56 | (1) |
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Taxation of Owners of Pass-Through Debt Certificates |
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57 | (1) |
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Taxation of REMIC Interest Owners |
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58 | (1) |
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Taxation of FASIT Interest Holders |
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59 | (1) |
| PART TWELVE TAXATION OF PHYSICAL COMMODITIES AND OPTIONS ON COMMODITIES |
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60 | (1) |
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61 | (1) |
| PART THIRTEEN TAXATION OF SECTION 1256 CONTRACTS |
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62 | (1) |
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General Tax Rules for Section 1256 Contracts |
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63 | (1) |
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Exceptions to Section 1256 Treatment |
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64 | (1) |
| PART FOURTEEN TAX CONSEQUENCES OF HOLDING OFFSETTING POSITIONS (STRADDLES) |
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65 | (1) |
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66 | (1) |
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Limitation on Recognition of Straddle Losses While Holding an Offsetting Position |
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67 | (1) |
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68 | (1) |
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69 | (1) |
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Disclosure of Unrecognized Gain |
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70 | (1) |
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71 | (1) |
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Modified Wash Sales and Short Sales Rules |
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72 | (1) |
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Capitalization of Straddle Interest and Carrying Charges |
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73 | (1) |
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Exceptions to Application of the Straddle Rules |
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74 | (1) |
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75 | (1) |
| PART FIFTEEN FOREIGN CURRENCY AND INTERNATIONAL OPERATIONS |
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Foreign Currency Transactions |
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76 | (1) |
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77 | (1) |
| PART SIXTEEN NOTIONAL PRINCIPAL CONTRACTS |
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Notional Principal Contracts |
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78 | (1) |
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Tax Considerations for Swap Transactions |
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79 | (1) |
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Caps, Floors, and Collars |
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80 | (1) |
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Sourcing Rules for Notional Principal Contracts |
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|
81 | |
| Appendix A Derivative Financial Product Transactions: Performing a Tax Analysis |
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A-1 | |
| Appendix B Analysis of Selected Foreign Futures Contracts |
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B-1 | |
| Appendix C Traded Foreign Currency Contracts |
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C-1 | |
| Appendix D Internet Addresses for Financial Product Sites as of August 1999 |
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D-1 | |
| Appendix E Treatment of Derivatives |
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E-1 | |
