Demystifying Section 1260--Using Options Under the Constructive Ownership Rules

© 2025 GlobalCapital, Derivia Intelligence Limited, company number 15235970, 4 Bouverie Street, London, EC4Y 8AX. Part of the Delinian group. All rights reserved.

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement | Event Participant Terms & Conditions

Demystifying Section 1260--Using Options Under the Constructive Ownership Rules

Section 1260 of the U.S. Internal Revenue Code (the "Code") was enacted in 1999 in response to a specific targeted tax planning strategy that involved writing derivatives on hedge funds.

Unlock this article.

The content you are trying to view is exclusive to our subscribers.

To unlock this article:

Request demo or Login
  • 4,000 annual insights
  • 700+ notes and long-form analyses
  • 4 capital markets databases
  • Daily newsletters across markets and asset classes
  • 2 weekly podcasts

Related articles

Gift this article