Apr 11, 2021 / by OsmondMarketing / No Comments

See also: 2017-15 Revenue Procedure, Qualified Intermediary Agreement The Securities Industry and Financial Markets Association (“SIFMA”)1 assesses the possibility of: submitting comments on the Qualified Intermediation Agreement (IQ) published in the 2017-15 2 Income Procedure (`QI Agreement` or `2017 ON the IQ Agreement`), which contains the requirements for qualified derivatives traders (“QDDs”) in accordance with the rules adopted under Section 871 (m) of the internal income code (“code”). Since the calculation of the net delta allows the use of the calculation used today for non-taxable commercial purposes, we ask you to confirm that QDS is flexible in determining its net exposure to the delta at the constituent or index level, provided it is consistent with its calculation of the net delta for non-tax purposes. If z.B. a QDD with respect to an exchange-traded fund or an eligible index takes a short delta-one position and then secures its short position by holding long delta-one positions in the fund or index components, it is not certain that the QDD will be able to determine its net delta with respect to the fund or index components. , as Section 871 (m) of the Regulations does not look at the components of the listed fund or the eligible index. The calculation of the net delta, which is now carried out by many equity derivatives traders, would generally include a fund or index to make these net positions down and give a more accurate risk assessment. Since the calculation of the net delta allows the use of the calculation used today for non-tax purposes, we ask for clarification that traders who deal with fund components or indices in order to isolate exposure to a certain capital guarantee are consistent with the definition of delta net exposure in the IQ agreement and can use them. To the extent that an IQ finds that it is an intermediary with respect to a securities loan or buy-re-transaction contract, that is, a type of code. Transaction 871 (m) is not treated as agreed by IQ as capital and, therefore, these transactions are not treated in the same way as that entered into by IQ in its QDD capacity.

The 2017 IQ agreement is for QIs who are qualified stockbrokers during 2017, since taxpayers can count on the rules of the LQS in 2017 in Communication 2010-46, I.R.B 2010-24, 757. Rev. Proc. 2017-15 follows the 2016-42 communication, published in July 2016, which contains a proposed IQ agreement (2016 Proposed IQ Agreement) containing provisions that contain conditions and requirements for QDD. The IRS has sought and received numerous stakeholder advice on the 2016 IQ agreement.