By contrast, net US Treasury positions rose during the financial crisis and are now net positive, as dealers have closed short positions (ie positions that rise in value when the price of an asset falls) and
accumulated securities holdings (Graph 3, left - hand panel).
This discussion also does not consider any specific facts or circumstances that may be relevant to holders subject to special rules under the U.S. federal income tax laws, including, without limitation, certain former citizens or long - term residents of the United States, partnerships or other pass - through entities, real estate investment trusts, regulated investment companies, «controlled foreign corporations,» «passive foreign investment companies,» corporations that
accumulate earnings to avoid U.S. federal income tax, banks, financial institutions, investment funds, insurance companies, brokers, dealers or traders in
securities, commodities or currencies, tax - exempt organizations, tax - qualified retirement plans, persons subject to the alternative minimum tax, persons that own, or have owned, actually or constructively, more than 5 % of our common stock and persons
holding our common stock as part of a hedging or conversion transaction or straddle, or a constructive sale, or other risk reduction strategy.