A bill to amend the Internal Revenue Code of 1954 with respect to straddles, and for other purposes.

Summary

Amends the Internal Revenue Code to provide that any loss which exceeds recognized gain from the holding of a straddle may not be recognized, for income tax deduction purposes, for the period during which a taxpayer holds such straddle, plus 30 days (or before the close of such period if the taxpayer disposes of all the positions which make up a straddle). Provides that the running of the required holding period for capital assets shall be tolled during the same period. Defines "straddle" 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 (commodities, evidences of indebtedness,currency, and other types of personal property). Creates a rebuttable presumption that two or more positions are offsetting, for purposes of the definition of a straddle, if: (1) the positions are customarily treated as such; (2) the aggregate margin requirement for such positions is lower than the sum of the margin requirement for each such position; or (3) there are other factors, as determined by the Secretary of the Treasury pursuant to regulations, which indicate that such positions are offsetting. Disallows as a deduction, and makes chargeable to capital account, interest and carrying charges with respect to personal property which is part of a straddle. 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. Excludes from capital gains tax treatment gain by a securities dealer from the sale or exchange of any security, unless the security was clearly identified in the dealer's records before the end of the day after the date of acquisition as a security held for investment (currently, before the end of the 30th day after the date of acquisition).

This text is taken from the official record. PoliticalRepo does not editorialize.

Timeline

No timeline events have been ingested for this record yet.

Votes

No vote records are attached yet.

Versions

No version snapshots stored. Document URLs remain at the source.

Documents

1 official file

• Introduced in House

  summary · EN · 27 January 1981

  Open at official source

Sponsors

No sponsors or actors listed by the source.

Related records

No cross-record relationships stored yet.