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Keep Your Eyes on Mark-to-Market

We report elsewhere in this issue on Senate Finance Committee Chair Ron Wyden's (D-Ore.) proposed mark-to-market tax on billionaires. On August 5, 2021, Wyden also introduced the Modernization of Derivatives Tax Act of 2021 (MODA). If enacted, MODA would impose mark-to-market treatment on all derivatives, tax gains and losses at ordinary rates, and source gains and losses based on the payee's residence. Regardless whether either proposal is enacted in its current form, the attention they have garnered suggests that more mark-to-market proposals are likely to be in our future.

Key Contacts

Adam Blakemore
Partner
T. +44 (0) 20 7170 8697
adam.blakemore@cwt.com

Linda Z. Swartz
Partner
T. +1 212 504 6062
linda.swartz@cwt.com

Jon Brose
Partner
T. +1 212 504 6376
jon.brose@cwt.com

Andrew Carlon
Partner
T. +1 212 504 6378
andrew.carlon@cwt.com

Mark P. Howe
Partner
T. +1 202 862 2236
mark.howe@cwt.com

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