Amends the Internal Revenue Code to postpone the recognition of losses, for income tax deduction purposes, which are generated from the sale of certain types of personal property (commodities other than those used in a taxpayer's business, evidences of indebtedness, and other types of personal property other than stock in a corporation) which are offset by the purchase of other personal property from which a gain is recognized. Provides that any loss which exceeds gain from the holding of such offsetting positions may not be recognized for the period during which a taxpayer holds such offsetting positions, plus 30 days. Provides that the running of the required holding period for capital assets shall be tolled during the same period.
Defines "offsetting positions" to mean that there is a substantial reduction of the taxpayer's risk of loss from holding any position with respect to personal property because the taxpayer also holds one or more other positions with respect to personal property (commonly referred to as a "straddle").
Creates a rebuttable presumption that two or more positions are offsetting if the positions are customarily treated as straddles, the aggregate margin requirement for such positions is lower than the sum of the margin requirement for each such position, or there are other factors, as determined by the Secretary of the Treasury pursuant to regulations, which indicate that such positions are offsetting.
Provides that obligations of the United States, a State or local government, or a U.S. possession, issued on a discount basis and payable without interest in less than one year shall be treated as capital assets in determining tax consequences of gain or loss with respect to such obligations.
Introduced in House
Introduced in House
Referred to House Committee on Ways and Means.
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