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Taxation of Foreign Exchange Gains and Losses

By Wahl, Jenny Bourne

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Book Id: WPLBN0000697075
Format Type: PDF eBook
File Size: 2.02 MB.
Reproduction Date: 2005

Title: Taxation of Foreign Exchange Gains and Losses  
Author: Wahl, Jenny Bourne
Volume:
Language: English
Subject: Government publications, Economics., United States. Department of the Treasury--Appropriations and Expenditures.
Collections: U.S. Department of the Treasury Collection
Historic
Publication Date:
Publisher: United States Department of the Treasury

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Wahl, J. B. (n.d.). Taxation of Foreign Exchange Gains and Losses. Retrieved from http://www.worldlibrary.in/


Description
Government Reference Publication

Excerpt
Introduction: The Tax Reform Act of 1986 (TU)substantially changed the taxation of foreign exchange gains and losses (FEGL). The principal objective underlying the new tax law on FEGL is to encourage the recognition of income on an economic rather than a tax-induced basis. This paper evaluates the extent to which that objective is reached. It begins by developing an optimal tax rule for FEGL in a simplified world, from the standpoint of worldwide efficiency. The optimal rule is recast to conform to existing U.S. tax law on other types of gains and losses. The reformulated rule, which treats expected and unexpected FEGL differently, departs from optimal taxation; As a result, capital may be misallocated. Moreover, taxpayers with the same realized income may not pay the same taxes and the fisc may be whipsawed. The reformulated rule is then compared to the TRA legislation and to pre-TRA law. The TRA rule does not generally adopt optimal taxation, nor does it implement the bifurcated rule consistent wit...

Table of Contents
Table of Contents Page I. INTRODUCTION 1 11. EQUILIBRIUM UNDER NO TAXES 2 111. OPTIMAL TAXATION 3 IV. FEGL TAXATION CONSISTENT WITH THE RESTRICTIONS OF EXISTING U.S.TAX LAW 7 V. U.S. LAW ON THE TAXATION OF FEGL 15 VI, SUMMARY AND CONCLUSIONS 20 APPENDIX 23 FOOTNOTES 28 BIBLIOGRAPHY 30 List of Tables CUMULATIVE TAX PAID UNDER VARIOUS SOURCING RULES FOR UNANTICIPATED FEGL 10 INCOME AND TAXES UNDER THE VARIOUS RULES 17 TAX RULES 26


 

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