Internal Revenue Bulletin – January 19, 2010 – Rev. Rul. 2010-3

Internal Revenue Bulletin – January 19, 2010 – Rev. Rul. 2010-3

Rev. Rul. 2010-3


Section 1256 contracts market to market. This ruling holds that the London International Financial Futures and Options Exchange (LIFFE), which is a United Kingdom derivatives market, is a qualified board or exchange within the meaning of section 1256(g)(7)(C) of the Code.

ISSUE

Is London International Financial Futures and Options Exchange (“LIFFE”), which is a regulated exchange of the United Kingdom, a qualified board or exchange within the meaning of section 1256(g)(7)(C) of the Internal Revenue Code?

LAW AND ANALYSIS

Section 1256(g)(7) provides that the term “qualified board or exchange” means:
(A) a national securities exchange which is registered with the Securities and Exchange Commission,
(B) a domestic board of trade designated as a contract market by the Commodity Futures Trading Commission, or
(C) any other exchange, board of trade, or other market which the Secretary determines has rules adequate to carry out the purposes of section 1256.

HOLDING

The Internal Revenue Service determines that LIFFE, which is a regulated exchange of the United Kingdom, is a qualified board or exchange within the meaning of section 1256(g)(7)(C).