Now in its fourth edition, this two-volume bound book provides a road map to work one’s way through the tax and regulatory maze of financial products. It details the policies, rules, and interpretations that govern the federal regulation and taxation of securities, crypto currencies, commodities, options, derivatives, and hybrid products. It provides reliable answers to questions about financial markets, financial products, and market participants, and it will help with planning transactions and defending challenged tax positions.
Part One: Overview of the Markets Part Two: Major Market Users Part Three: Tax Classifications of Financial Market Participants Part Four: Taxation of Capital Transactions Part Five: Ordinary Income Transactions Part Six: Anti-Abuse Considerations Part Seven: Terminations of Contract Rights and Obligations Part Eight: Dividends, Interest, Security Loans, and Repurchase Transactions Part Nine: Equity Securities, Options, Partnerships, and Publicly Traded Trust Interests Part Ten: Debt Securities and Options on Debt Securities Part Eleven: Asset-Backed Securities Part Twelve: Commodities, Options on Commodities, and Bitcoin and Virtual Currencies Part Thirteen: Section 1256 Contracts Part Fourteen: Straddles Part Fifteen: Foreign Currency and International Operations Part Sixteen: Notional Principal Contracts
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The developer and presenter of the Financial Products Tax Building Block Series is Andrea S. Kramer, a nationally recognized expert in financial products, including their taxation regulation, purposes and usage, and documentation. She is the author of Financial Products: Taxation, Regulation and Design published by Wolters Kluwer. She is a partner at McDermott Will & Emery, leading its Financial Products, Trading and Derivatives group.
Chambers USA has ranked Andie as a Leading Individual in Tax for her “expert opinions on the taxation of financial products," her “expertise in the tax treatment of financial instruments and derivatives," her “very acute mind when it comes to securities and financial instruments taxation," her “unbelievable energy," and “her considerable expertise in energy matters, including the field of renewable energy sources." The Legal 500 United States has ranked Andie as a Leading Lawyer in Tax, as “widely recognized as one of our nation's most important voices in financial market tax-policy," “the best of class in a generation of lawyers," whose “response times are excellent," and who “takes a deep and active interest in tax policy development." The Legal 500 United States also ranked Andie as a Leading Lawyer in Domestic Tax and as a Leading Lawyer In Structured Finance and Derivative Products and she is “highly recommended for her energy, competence and impressive standards," as “a brilliant tactician and a first-rate legal scholar" who is “detailed and thorough in her legal analysis and advice" and “shares the client's urgency" and whose “expertise in financial derivatives is outstanding." The National Law Journal recognized her as one of the 50 Most Influential Women Lawyers in America.
Andrea Kramer is a partner in the international law firm of McDermott, Will & Emery, resident in its Chicago office. She is head of the firm’s Financial Products and Derivatives group. Ms. Kramer is a graduate of the University of Illinois and of Northwestern University School of Law. She is recognized as a leading commentator on financial products and derivatives. She is an adjunct professor of law at Northwestern University School of Law, teaching two courses on derivative products. She is also a frequent contributor to trade and professional journals.
NICHOLAS C. MOWBRAY is an associate resident in the Washington D.C. office
of Baker & Hostetler LLP. His practice focuses on international tax and financial
products tax matters, where he advises funds, investment managers, multinationals across various industries, and individuals on financial products matters, including issues associated with debt, commodities, derivatives, and cryptocurrencies, rules affecting market participants (that is, investors, traders, dealers, and hedgers), and international tax matters such as transfer pricing, treaty applicability, the anti-hybrid rules, GILTI, subpart F income, FDII, and foreign tax credit planning.
Mr. Mowbray is a graduate of the University of Michigan (B.A.), Chicago-Kent
College of Law (J.D.), and Northwestern University (LL.M). He is a member of the
Illinois and Washington D.C. Bars. He has worked with Andie Kramer on updates to
Financial Products: Taxation, Regulation, and Design since 2011.
