7/3/2014 Daily Tax Report Bloomberg Daily Tax Report® BNA Source: Daily Tax Report: News Archive > 2014 > July > 07/01/2014 > Tax Decisions & Rulings > Accounting: Switch From Treating Basket Transactions As Options an Accounting Change, CCA Says 126 DTR K-2 Accounting Switch From Treating Basket Transactions As Options an Accounting Change, CCA Says June 30 — The Internal Revenue Service Office of Chief Counsel in a chief counsel advice memorandum said that when a taxpayer stops treating certain securities transactions as "options," and thus no longer defers associated gains, losses, income or deductions, it is a change in accounting method under tax code Section 446. Section 481(a) applies in such a situation, the office said in CCA 201426025, released June 30, so computation and recognition of an appropriate adjustment is needed to eliminate any distortions in income or deductions caused by the accounting method change. The CCA considered a situation where a limited liability company, treated as a partnership for federal tax purposes, conducts daily trading in securities positions, mainly through various basket transactions with a broker and investment bank. Typically, the taxpayer makes an up-front payment of 10 percent of the notional amount of the basket of securities and the bank provides the remaining 90 percent. The year-plus contract describes the LLC's investment as a "premium" giving the LLC the "option" to receive a cash settlement from the bank when the contract expires or is terminated. The cash settlement amount is determined by formula and generally reflects the increase or decrease in the securities' value, less expenses, interest and fees payable to the bank for its services and capital. The taxpayer doesn't recognize gains, losses, income or deductions as it trades the securities within the basket, instead deferring recognition until the contract is ended. The taxpayer recognizes gain equaling the difference between