US Taxation of Foreign Currency Derivatives: 30 Years of Uncertainty

Bulletin for International Taxation, IBFD, Vol. 64, No. 3, March 2010

In this text, Viva looks at how 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 rules. Hammer specifically, questions does this rule apply to foreign currency forwards only or to options, swaps, and other derivatives as well?