Case Study
$2.1M Kalshi Trading Volume — Defensible Tax Position Built from No Framework
The Problem
Client assumed gains from hundreds of Kalshi contract dispositions qualified for Section 1256 treatment by default. No formal tax framework, no transaction-level documentation, and no audit defense position were in place. Exposure included recharacterization to ordinary income or wagering treatment, loss limitation mismatches under Section 165(d), and inconsistent reporting across the portfolio.
What We Did
Performed a contract-level classification analysis evaluating four frameworks: Section 1256 regulated futures, capital asset treatment, ordinary income, and Section 165(d) wagering. Built a formal position memo supporting the selected treatment with documented rationale for each framework assessed and rejected. Reconstructed the full transaction history across all contracts and standardized reporting methodology across the entire portfolio.
The Outcome
Established a defensible reporting position aligned with the client's actual trading activity. Eliminated risk of inconsistent treatment across contracts. Delivered filing consistency across the full portfolio with a documented, audit-ready methodology the client can carry forward year over year.
