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Lesson 16 of 25 · 7 min

Offsetting-position rules, at a mechanical level

A loss on one leg is held back by an unrecognised gain on the other, and waits for it.

Two positions that move against each other create a specific problem for any system that counts gains and losses at different moments: the loss can be taken now and the gain left for later.

Offsetting-position rules close that gap by mechanical means. Where two positions substantially reduce each other's risk, a loss realised on one leg is held back to the extent of unrecognised gain remaining in the other. The held-back amount is generally not destroyed; it waits, and it becomes available when the offsetting gain is itself recognised or the offset ends.

The arithmetic is a comparison of two figures. Close the offsetting leg at a loss of $138,400 while the position it offsets carries $151,900 of unrecognised gain, and the whole loss is held back, because $138,400 does not exceed $151,900. Change the unrecognised gain to $46,000 and $46,000 of the loss is held back while $138,400 − $46,000 = $92,400 becomes available. The loss did not change at all. The other side of the pair did.

A second mechanic often travels with the first. Interest and carrying costs attributable to an offsetting position may be added to the basis of the position rather than relieved in the period, so a cost that would otherwise reduce income this year instead reduces a gain at some unknown future date. Treat $9,250 of carrying cost that way and it is not lost, but it has moved to a different year and a different category.

Systems differ on the definition of substantially reduced risk, on which instruments are within scope, and on what identification or record-keeping is required. The mechanism is general; the treatment is not, and the difference belongs with a qualified adviser.

Key terms

Offsetting-position rule
A rule holding back a loss on one leg of a paired position to the extent of unrecognised gain in the other leg.
Held-back loss
A realised loss that cannot be used yet. It generally survives and becomes available when the offsetting gain is recognised or the pairing ends.
Capitalised carrying cost
A financing or holding cost added to the basis of a position instead of reducing income in the period it was paid.

Worked example

The same loss, two different other sides

A loss of $138,400 realised on one leg of a paired position, tested against the unrecognised gain in the other.

Loss realised on the offsetting leg
$138,400
Unrecognised gain in the position it offsets
$151,900
Loss held back
$138,400

$138,400 does not exceed $151,900.

Loss available in the period
$0
Same loss where the unrecognised gain is $46,000
$46,000 held back
Loss then available
$92,400

$138,400 − $46,000.

The loss was identical in both columns. What decided its availability was a figure in a position that had not been touched.

Check yourself

A $138,400 loss is realised on one leg of a paired position. In one case the other leg holds $151,900 of unrecognised gain; in the other it holds $46,000. What is available in each case?

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Educational only. Nothing in this lesson is investment, legal or tax advice, or a recommendation to enter into any transaction. Figures are illustrative and computed from the inputs stated in the lesson.

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