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Tax News
Archive - March 2014
Notice 2014-21: Treasury Lays the Law on Bitcoin
Notice 2014-21: Treasury Lays the Law on Bitcoin
The investment fund industry's involvement in Bitcoin is in its nascent stages. Some early adopters, however, believe that this is the future. The Winklevoss brothers have been working on launching the first Bitcoin ETF and Second Market has already launched the first Bitcoin Investment Trust.  On the hedge fund front, Pantera Capital recently registered Pantera Bitcoin Advisers with reportedly a total value of $150m. Apparently Fortress is behind the fund. Separately, there are a myriad of pool vehicles that mine Bitcoins. These are basically online portals where individual or enterprises...
March 26, 2014 read more
Should the Reduction in a Listed Option Premium for an Estimated Dividend be Treated as a Dividend Equivalent Payment under 871(m)?
Should the Reduction in a Listed Option Premium for an Estimated Dividend be Treated as a Dividend Equivalent Payment under 871(m)?
The 2013 871(m) proposed regulations have left many in the hedge fund, trading and securities industries up in arms. I recently pointed out here that the regulations as drafted would subject some single stock futures to withholding.  I did not focus on listed options, but I recently read a great comment by the U.S. Securities Markets Coalition which basically highlights the same problem for options.  In this blog entry, I’d like to lay out my 2c on this issue. What is the problem? The problem is that the formula for calculating the premium on listed options includes an estimate for...
March 10, 2014 read more