While analyzing the various problems of our subject, one arrives at the question according to : this is the tax question which influences the problems of the recasting of the local public action or it is the need for recasting of the local public action which requires one reforms in-depth taxation. In fact, both closely seem dependant. Consequently, the question of the reform of the local taxation should not be apprehended that within the framework of the reflection on the face which one wants to give to decentralization.
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By making the current assessment of the situation, one can only be perplexed as for the existence of a real political good-will going in this direction. The great questions raised by tax specialization seem still far away from the concerns of the moment. In this direction, one can say that if the way of territorial tax specialization appears theoretically interesting and seems to make consensus among the analysts and the specialists in local finances, it is mainly rejected within the national and local political elites.
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Futures on Ether or other actively traded virtual currencies could be section contracts in the future. Section treatment does not apply to qualified hedging transactions, identified section d mixed straddles where mixed straddle election has been made , or mixed straddle accounts.
Section is not elective. Transactions that meet these definitions are subject to these two rules, discussed in what follows. The mark-to-market rule provides that section contracts open on the last day of the taxable year are marked-to-market; that is, treated as if they were sold on that date.
All unrecognized gains and losses are taken into account. In other words, open section futures and options are treated as if they were sold for their fair market value on the last business day of the taxable year.
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The fair market value of such futures or options is their settlement prices. For Bitcoin futures and options, for example, their settlement prices are determined by the CME on the last business day of the taxable year I. All gains and losses are tallied up and used to compute taxable income. When taxpayers terminate Bitcoin futures or options during the year by offset or otherwise , these contracts are taxed at their sale or close-out price I.
Because taxes are paid on recognized and unrecognized gains and losses, taxpayers holding Bitcoin futures and options can be required to pay tax on gain that, in fact, they may never actually realize. On the other hand, a taxpayer can report a mark-to-market loss on a section contract that is never realized.
Gains sur bitcoins : quelle fiscalité ?
If they continue to hold contracts that were marked-to-market at year end, gains and losses realized in a subsequent tax year are adjusted to reflect gains and losses taken into account in the preceding taxable year I. The mark-to-market rule can, therefore, distort income and cause economic hardship if gains that were reported in the first year do not materialize in a subsequent tax year.
The mark-to-market rule applies to all section contracts, without regard to whether they are ordinary or capital, unless the taxpayer is a hedger that made a valid hedge identification.
If taxpayers hold tax straddles that consist only of Bitcoin futures and options, the general straddle rules of I. This is because the mark-to-market rule taxes all gains and losses on section contracts as of the last business day of the taxable year, preventing taxpayers from deferring their gains or accelerating their losses.
Taxpayers who hold futures or options that qualify as section contracts might also hold actual virtual currencies or other derivatives. Straddles that include both section contract positions and non-section contract positions are treated as mixed straddles, subject to various elections available to mixed straddles. Eligible taxpayers can use their section losses incurred in one year to reduce income generated on such contracts in prior tax years. This carryback rule provides a form of income averaging not available to other taxpayers.
Taxpayers can carry net section contract losses back to each of the three preceding years and apply the losses against net section contract gains recognized in those prior years I. Carryback losses cannot be used to increase or produce a net operating loss for the prior taxable year I. Such losses are carried back to the earliest of the three preceding taxable years in which there is a net section contract gain I. Any portion of the loss not absorbed in the earliest year can then be carried forward to the next taxable year and, if any loss remains, to the next most recent taxable year I.
The loss carryback election is quite complicated in its application, applying only after netting section contract losses with unrelated capital gains and losses. Taxpayers should keep these special rules for section contracts in mind for their Bitcoin futures and options and for other positions in other virtual currencies, such as Ether futures, to determine whether they qualify for section treatment when QBEs begin trading futures and options on additional virtual currencies. June 17, Andrea S.