Taxation of Professional Stock Traders

The tax rules for stock investors in general requireslong-term capital gains tax rates (currently 15%).
three steps. Step one is the netting of short-termTraders are also eligible for certain deductions that
capital gains and short-term capital losses. Step two isare not available to investors. One such deduction is
the netting of long-term capital gains and long-termthe home office deduction. Traders may use their
capital losses. Step three is the netting of net shortnet income from trading activities to fund a SEP-IRA,
term gains/losses and net long-term gains/losses. Anyand thus further reduce their taxable income. Another
capital losses in excess of $3,000 are carried forwardsuch deduction available only to traders is interest
indefinitely to offset future capital gains plus $3,000expense. Investors are limited to deducting interest
of ordinary income every year, until the capital lossesexpense incurred on debt used to finance their
are used up. But what if you are a "day trader"?investment activities to investment income (gains,
What special tax rules exist for day traders? Thisdividends and interest income). This limit on deducting
article will address those unique tax rules that applyinterest expense to the extent of investment
to day traders.income, is not applicable to traders. Traders may
What is a day trader? In general, a day trader, isdeduct their interest expense as a deduction on
anyone who engages in the business of tradingSchedule C. Lastly, wash sale rules, which apply to
stock. You are in the business of trading stock, andinvestors, do not apply to traders. The wash sale
thus not an ordinary stock investor, when therules require the deferral of trading losses, where the
frequency of your trading activity is such that itinvestor acquires substantially identical stock or
meets the "material participation" test. Qualifying as asecurities within thirty days before or after a sale
trader under this material participation test is difficultgenerating a loss.
because one must be active in the securities marketsSo how do you make the leap once you have
on a daily basis and attempt to profit fromdetermined that you are in the business of trading?
short-term swings in security prices. Many onlineTraders who desire to be treated at in the business
investors fail this test, but some day traders (mostof trading stocks make an election called the
of whom are also online investors) meet theMark-To-Market election by April15th of the current
standard. InPurvis [37 AFTR2d 76-968, 530 F2d 1332year. To be treated as a trader for 2010, a trader
(1976, CA-9)], the Ninth Circuit Court of Appealsmust make this election by April 15th, 2010, which is
upheld a prior tax court decision [Purvis, TC Memoattached to either their 2009 Form 1040 or attached
1974-164 (1974)] and agreed with the Tax Court thatto their 2009 extension.
in order to be classified as trading, the activity shouldElection language:
be performed with sufficient frequency to "catch theTaxpayer hereby elects under IRC Sec. 475(f) to use
swings in the daily market movements and profitthe mark-to-market method of accounting for
thereby on a short-term basis." Day traders can takesecurities. This election will first be effective for the
a buy-and-hold approach, but most of them seek totax year ended December 31, 2010. The election is
take advantage of short-term market fluctuationsmade for the following trades (list trades).
and this short-term market fluctuation criteria is theOnce this election is made it is effective for all future
linchpin in qualifying some day traders as traderstax years. The mark-to-market election requires
rather than investors for federal income taxtraders to mark their stock holdings to market value
purposes.at the end of the tax year. Once made, all security
What's so important about being considered a tradergains and losses are treated as ordinary income or
verses an investor?losses and all trading securities on hand at the end of
Investor losses in excess of $3,000 a year are notthe year are deemed to be sold (and repurchased)
deductible in the year of the loss. This excess lossat the year-end market value. All unrealized (unsold
amount must be carried forward. There is no timesecurities) gains and losses recognized under the
limit on the future utilization of the excess losses, butmark-to-market election increase (unrealized losses)
if you continue to rack up losses each year, you willor decrease (unrealized gains) their basis in a given
be limited, each year, to this $3,000 loss limitation.security.
Traders, on the other hand, are not limited to thisBecause making the mark-to-market election can
$3,000 annual loss limitation. They are able to deducthave significant tax ramifications to future trading
their entire net loss for the year on their individualactivities you should first consult with your CPA to
income tax return. Traders report their net gainsdetermine if your trading activities meet the material
losses on Form 4797 as ordinary income (investorsparticipation test and, if so, if this election makes the
report their net gains/losses on Schedule D. Netmost sense to your future trading business.
long-term capital gains are taxed at the favorable