Tax practitioners will sometimes encounter derivatives and even repos and stock loans in relation to the transactions they advise upon. Such derivatives repos or stock loans may be central to the transactions in question or play a more ancillary role such as the conversion of floating rate interest payments under a borrowing into fixed rate ones by means of an interest rate swap (see also below). Two key questions usually arise in relation to this type of transaction: how and where are they taxed and what tax-related provision needs to be made for them...
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Tax practitioners will sometimes encounter derivatives and even repos and stock loans in relation to the transactions they advise upon. Such derivatives repos or stock loans may be central to the transactions in question or play a more ancillary role such as the conversion of floating rate interest payments under a borrowing into fixed rate ones by means of an interest rate swap (see also below). Two key questions usually arise in relation to this type of transaction: how and where are they taxed and what tax-related provision needs to be made for them...
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