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U.S. Taxation of Foreign Currency Transactions: A View from Traders' and Hedgers' Perspectives

By: Tannenbaum, Elliot | The CPA Journal, September 1991 | Article details

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U.S. Taxation of Foreign Currency Transactions: A View from Traders' and Hedgers' Perspectives


Tannenbaum, Elliot, The CPA Journal


Over the past several years, new tax laws and regulations have provided guidance that has significantly clarified the taxation of foreign currency transactions. Prior to this, U.S. taxation of many of these transactions was, at best, unclear. While the laws and underlying regulations have gone a long way towards providing necessary guidance, foreign currency traders and hedgers (e.g., multinational U.S. corporations) must work their way through complex rules. The following example provides an overview of the U.S. tax consequences to both foreign currency traders and hedgers entering into a foreign exchange forward contract.

Example: On September 30, 1991, a U.S. multinational …

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