TAX--Treatment Accorded Foreign Currency Debt Redemption Gains and Looses: National-Standard Co. v. Commissioner

Ross, Thomas G.
June 1984
Journal of Corporation Law;Summer84, Vol. 9 Issue 4, p951
Academic Journal
The purpose of this comment is to determine the proper tax treatment to accord foreign currency debt redemption gains and losses arising from exchange rate fluctuations. First, the comment presents a brief history of the tax treatment accorded foreign currency debt redemption gains and losses. Second, the comment sets out and analyses the National-Standard Co. v. Commissioner decision. Third, the comment examines the impact of National-Standard on, and the future development of, the tax treatment to be accorded future foreign currency debt redemption gains and losses caused by fluctuations in exchange rates. Finally, the comment concludes that foreign currency gains and losses, arising from exchange rate fluctuations, should be treated the same as a short sale of a foreign currency and accorded capital gains treatment.


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