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JCT Report: Modernizing Derivatives Legislation Introduced (IRC §1234) – Bloomberg Tax

Aug. 5, 2021, 5:00 AM

Description of S. __, the Modernization of Derivatives Tax Act of 2021 (MODA), provided in a Joint Committee on Taxation report released August 5. The legislation, introduced August 5 by Sen. Wyden (D-OR), would unify and simplify the treatment of derivatives, providing one timing rule, one character rule, and one sourcing rule for all derivatives, the JCT noted. The bill would expand the scope of the mark-to-market timing rule to a broader class of taxpayers and arrangements than has been subject to such a rule in the past and gain or loss from derivatives and certain related assets would be …