Reg. § 1.246-5(c)(1)(iii)

substantial overlap: Step Two, for the whole position or the largest percentage of it that overlaps (Step Three)

UNDECIDED

0 of 2 settled

  1. 1

    Reg. § 1.246-5(c)(1)(iii)

    ALL OF
    “the fair market value of the Subportfolio is equal to or greater than 70 percent of the fair market value of the stocks represented in the position” Reg. § 1.246-5(c)(1)(iii)(B)

    Step One builds the Subportfolio: for each stock in the position, the lesser of its value in the position and in the holdings, (c)(1)(iii)(A). Short of 70 percent, Step Three repeats Steps One and Two on a smaller position; the largest percentage that overlaps is substantially similar or related to its Subportfolio, (c)(1)(iii)(C)

    Step 2 substantial overlap UNDECIDED

  2. 2

    Reg. § 1.246-5(c)(1)(iii)(B)

    substantial overlap

    ALL OF
    “the fair market value of the Subportfolio is equal to or greater than 70 percent of the fair market value of the stocks represented in the position”

    Subportfolio: Step One, (c)(1)(iii)(A). Short of 70 percent, Step Three tests a smaller part of the position, (c)(1)(iii)(C)