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The New Tax Whipsaw for Swaps  


Author:  Mark Fichtenbaum.; Robert Gordon.


Source: Volume 35, Number 03, Spring 2018 , pp.3-5(3)




Journal of Taxation of Investments

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Abstract: 

The Tax Cuts and Jobs Act of 2017 created an adverse effect on individuals and investor partnerships that use notional principal contracts (swaps) in their investment activities. Profits will be subject to tax but losses will be non-deductible. The article also explores some possibilities to reduce the impact.

Keywords: notional principal contracts, miscellaneous itemized deductions investment partnerships, IRC Sec. 212, Tax Cuts and Jobs Act of 2017

Affiliations:  1: MF Consulting; 2: Twenty-first Securities.

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