Sentences with phrase «currency hedging transactions»

The Portfolio will generally treat gains or losses on non-U.S. currency hedging transactions as capital gains or losses in accordance with the advice of counsel and the current administration position of the CRA, but if such transactions were treated on income rather than capital account, after tax returns to unitholders could be reduced and the Portfolio could be subject to non-refundable income tax.

The Portfolio will then enter into non-U.S. currency hedging transactions to hedge the exposure of the net asset value of units of the Underlying Funds held by the Portfolio to fluctuations in the value of non-U.S. currencies.

The non-U.S. currency hedging transactions will involve using derivatives such as options, futures, forward contracts, swaps and other similar instruments.

Not exact matches

Such hedging functions have particularly unique promise because of the extremely low transaction costs of peer - to - peer currency.

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.

The iShares Currency Hedged ETF's use of derivatives may reduce the funds» returns and / or increase volatility and subject the funds to counterparty risk, which is the risk that the other party in the transaction will not fulfill its contractual obligation.

Adjusted EBITDA and segment Adjusted EBITDA reflect adjustments for interest expense, net, income tax expense (benefit), depreciation and amortization, including accelerated depreciation, and the following adjustments discussed above: non-cash mark - to - market adjustments and cash settlements on interest rate swaps, provision for legal settlement, transaction costs and integration costs, restructuring and plant closure costs, assets held for sale, inventory valuation adjustments on acquired businesses, mark - to - market adjustments on commodity and foreign exchange hedges and foreign currency gains and losses on intercompany loans.

The iShares Currency Hedged Funds» use of derivatives may reduce the Funds» returns and / or increase volatility and subject the Funds to counterparty risk, which is the risk that the other party in the transaction will not fulfill its contractual obligation.

Transactions entered into through a Member to hedge currency exposure from positions on regulated exchanges are exempt from all forex requirements except sections (b) and (c) of this rule if the on - exchange transactions are handled by the Transactions entered into through a Member to hedge currency exposure from positions on regulated exchanges are exempt from all forex requirements except sections (b) and (c) of this rule if the on - exchange transactions are handled by the transactions are handled by the same Member.

In addition, no assurance can be given that the Fund will enter into hedging or other transactions (including hedging exposure to non-U.S. currency exchange rate risk) at times or under circumstances in which it may be advisable to do so.

To the extent such investments are permissible, a certain percentage of a Fund's hedging activities (including its transactions, if any, in foreign currencies or foreign currency - denominated instruments) are likely to produce a difference between its book income and its taxable income.

Hence, real estate transactions will have an element of hedging and speculative currency trading as part of their normal risk profile.

Robb regularly advises clients on tax issues relating to domestic and foreign public and private debt offerings, synthetic and hybrid instruments, foreign currency transactions, swaps and derivatives, hedging transactions and other complex financial products and transactions.

Advise on all tax considerations, including income recognition, constructive sales, straddle rules, hedging transactions, non-functional currency issues, dividend - equivalent payments, recharacterization, withholding taxes, reporting and compliance and FATCA.

Currently, Ripple requires two parties for a transaction to occur: a regulated financial institution «holds funds and issues balances on behalf of customers» while «market makers» such as hedge funds or currency trading desks provide liquidity in the currency they want to trade in.

Furthermore, businesses that have avoided using Bitcoin as a form of payment for large - scale transactions that involved terms, due to the unpredictable volatility of the currency, will now be able to guarantee the value of a transaction using futures contracts to hedges against adverse market price movements, similar to the way businesses handle international transactions.