Volume 39 (2011) / Issue 8/9
Existing accruals/realization tax borderlines differ by jurisdiction and are generally incapable of dealing consistently with many innovative structured financial instruments, particularly hybrid instruments and those incorporating both fixed and contingent returns. This article develops a new analytical approach to defining the accruals/realization tax borderline, which does not disturb, and is consistent with, the existing realizations treatment of shares and the accruals treatment of bonds. The approach relies on a single, standard measure of risk, the annualized volatility of returns. The approach provides a unique solution for all innovative financial instruments and could have application in all jurisdictions.
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