Synthetic prime brokerage and the risk of tax recharacterisation: Difference between revisions
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{{a|spb|[[File:Dramatic Look Gopher.gif|thumb|center|450px|DID SOMEONE SAY [[recharacterisation|RECHARACTERISATION]]??]]}} | {{a|spb|[[File:Dramatic Look Gopher.gif|thumb|center|450px|DID SOMEONE SAY [[recharacterisation|RECHARACTERISATION]]??]]}}Controversial view, perhaps, but the tax disposition which led to someone inventing the “[[hypothetical broker dealer]]” — a creature as beloved of the [[equity swap]] market as the [[reasonable man]] is of the [[common law]] — is, in [[this commentator]]’s view, predicated on a fundamental misapprehension as to how a [[synthetic equity swap]], and the [[hedging]] and financing behind it, works. | ||
Controversial view, perhaps, but the tax disposition which led to someone inventing the “[[hypothetical broker dealer]]” — a creature as beloved of the [[equity swap]] market as the [[reasonable man]] is of the [[common law]] — is, in [[this commentator]]’s view, predicated on a fundamental misapprehension as to how a [[synthetic equity swap]], and the [[hedging]] and financing behind it, works. | |||
This fear of “[[recharacterisation]]” — obligatory nod to our [[dramatic look gopher]] — also disregards the [[IRS]]’s known acknowledgment that [[synthetic equity swap]]s are a thing; a bona fide class of transactions of genuine utility and wide use in the market. | This fear of “[[recharacterisation]]” — obligatory nod to our [[dramatic look gopher]] — also disregards the [[IRS]]’s known acknowledgment that [[synthetic equity swap]]s are a thing; a bona fide class of transactions of genuine utility and wide use in the market. | ||