EFTA02711179Set 11
2014-01-179p6,750w
such
positions. Taxpayer has conducted much of its securities trading under various "Barrier Basket
Transactions" (Basket Transactions) with Bank, a broker and investment bank. In a typical Basket
Transaction, Taxpayer ... makes an upfront payment of 10 percent of the notional amount referenced in
the Basket Transaction. Bank provides the remaining 90 percent, the total amount of which is used ... payments made or received with respect to the
securities held and traded within the Basket Transaction and the interest and fees payable to Bank
for its services and capital. Taxpayer
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02711179.pdf
EFTA01193903Set 9
2014-01-179p6,733w
such
positions. Taxpayer has conducted much of its securities trading under various "Barrier Basket
Transactions" (Basket Transactions) with Bank, a broker and investment bank. In a typical Basket
Transaction, Taxpayer ... makes an upfront payment of 10 percent of the notional amount referenced in
the Basket Transaction. Bank provides the remaining 90 percent, the total amount of which is used ... payments made or received with respect to the
securities held and traded within the Basket Transaction and the interest and fees payable to Bank
for its services and capital. Taxpayer
https://www.justice.gov/epstein/files/DataSet%209/EFTA01193903.pdf
EFTA02711177Set 11
2014-07-032p781w
Report: News Archive > 2014 > July > 07/01/2014 > Tax Decisions & Rulings > Accounting: Switch
From Treating Basket Transactions As Options an Accounting Change, CCA Says
126 DTR K-2
Accounting
Switch From Treating ... Basket Transactions
As Options an Accounting Change, CCA Says
June 30 — The Internal Revenue Service Office of Chief Counsel in a chief counsel
advice memorandum said that when a taxpayer ... partnership for federal
tax purposes, conducts daily trading in securities positions, mainly through various basket
transactions with a broker and investment bank. Typically, the taxpayer makes an up-front payment
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02711177.pdf