Capital Gain Treatment of Currencies

Sep 30, 2012 8 Replies

It is becoming increasingly common for US retail brokerages to let customers hold foreign currencies. Sometimes this is done as an outright currency investment, and other times it is a byproduct of buying or selling a foreign stock. Interactive Brokers in the US was the first to pioneer this, and Schwab and others are following their lead. This raises the interesting question what is the capital gain/tax treatment of holding a foreign currency, if you take a gain or loss going from and to US dollars?



Brokers create a 1099 at the time you sell a foreign stock. They use USD value at time of purchase as the cost basis, and USD value of the stock at time of sale as the value to calculate gain or loss. These stock values in USD are what goes on the broker's 1099-B.



Apparently the brokers do not record capital gains information for pure currency holdings in a 1099. Calculating it on your own is next to impossible. How can you distinguish Canadian dollars held that were converted from USD and held as Canadian dollars forever, from some subset of that currency that ended up buying and selling some Canadian stock multiple times ? Keeping track of when the currency was being held as part of a stock investment and when it was part of a currency holding, would be a horrificly complex reconciliation to perform. What are tax reporting rules regarding currencies?


I believe you only have to calculate the capital gain on currency holdings when you convert it back to US dollars. Otherwise you'd be paying taxes on unrealized currency gains. But some questions arise: is the gain ordinary or capital, are losses allowed.

The problem is the broker's 1099 will double count some part of a simple currency gain calculation. If the sequence is:

A) Buy Australian dollars with US dollars B) Buy at later date Australian stock X C) Sell Australian stock X D) Convert at later date Australian dollars to US dollars

The broker's 1099 makes a currency conversion calculation just to report the sale of stock in step C). If you need to report the currency gain or loss between A) and D), you somehow need to back out the component of that gain or loss already reported on the 1099 that reports steps B) and C).

It's tedious accounting at best.

If your accounting currency is USD, isn't step C really an exchange of the stock for AUD? Then step D is a sale of the AUD.

R's, John

Yes step C is a sale for AUD. The problem is that is not the way the broker

*reports* it on the 1099-B. Brokers make a conversion to USD at time of sale in C and report to the IRS as if you had done step D) at that point in time.

To do it as you suggest, how could you report the the capital gain or loss in C) without making a conversion to USD? In any case you would need to deviate from the broker's 1099-B, which carries its own issues.

I'm not sure there is any clean solution.

You might think so, but it still generates a capital gain transaction (which A and B don't, and D does).

Or, visit Australia and _spend_ the AUD (if AUD appreciated). There's no tax on the AUD appreciation that way.

Seth

An example might make understanding easier. Then 1099 tracks B and C. So suppose 1.3 USD = 1 EUR. You convert $100 to euros, getting 77 EUR, and immediately thereafter buy 77 EUR worth of stock. The stock rises to 100 EUR, but at that time the exchange rate is 1 USD = 1 EUR. You sell the stock, and immediately convert to dollars. The 1099-B has the cost as $100, and proceeds as $100, netting a profit of zero.

So the key is how are these international trading accounts set up. If the money is held in USD, and converted at the point of purchase and sale to/from the foreign currency, then there is no issue.

But if the account lets you hold international currency for a while then buy stock, then you have a problem. Because you will convert $100 to EUR, getting 77 EUR. You let the money sit there collecting EUR interest. Each interest payment must be converted on the day received to USD, and the broker can probably do that for you and put it on the 1099-INT. Suppose the interest is zero. Then you wait two months, the exchange rate changes to 1 USD = 1 EUR . Now you buy stock worth 77 EUR. Your purchase price ought to be $77, which is the purchase price of the stock. You sell the stock for 78 EUR, but by now the exchange rate is 1 USD = 0.9 EUR, so the sale price is

78/0.9 = $87. So the 1099-B will show purchase of $77 and sale of $87, profit of $10. Yet the account has only 1 EUR in it, yet you owe the IRS profit on $6 capital gain. If you sold at 76 EUR, there would be a loss in the foreign account, but the US 1099-B would have a gain! Now going back, you have 1 EUR in the account, and you convert it later when the rate is 1 USD = 0.8 EUR, yielding you $1.25.

I have no idea how to handle this!

I'm not sure about that. It sounds like a loophole, and I'm sure some statute or law prohibits it.

Two errors here: the account has 79 EUR in it, not 1 EUR, after the sale for 78 EUR. You owe the IRS tax on $10 of gain, not $6.

You add the USD gain (or subtract the loss) to your basis in the EUR you hold. So, in the case of the sale for 78 EUR ($87 USD), you have 78 EUR with a cost basis of $110. If you then convert the EUR back to dollars when the exchange rate is $1 = 0.8 EUR, you receive $97.50 for a loss of $12.50 due to exchange rate fluctuations.

It's not a loophole. It's the same as if you were to travel to any other foreign country and spend dollars you converted into the local currency. There is no gain/loss due to exchange rates. Conversely, if you travel to a foreign country and convert USD into that currency and then convert the unspent local currency back into USD at the end of the trip, you can (and should, in principle) report the gain/loss due to exchange. This will almost always be a loss due to exchange fees and the spread between currency bid/ask rates.

Ira Smilovitz

You have to report a gain. A loss may be personal (e.g. vacation trip) hence not deductible.

Seth

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