The Problem
The firm traded event contracts for its own account through automated systems at institutional scale, across multiple contract categories, with active members in several states and ownership that had changed during the period. Prediction markets sit across derivatives, wagering, property, and partnership rules, and no federal authority directly addresses the specific combination of standardized, centrally cleared, fully collateralized contracts the firm was trading. The firm needed a framework that answered, position by position, what was acquired, when a taxable event occurred, what the legal endpoint was, and which character rules applied.
What We Did
We built the evidence record before reaching tax conclusions, converting the raw trading and organizational material into controlled workpapers covering contract and category inventory, exchange and clearing mechanics, full-population trade analytics, profit attribution, and the ownership and election history. Each position was mapped from acquisition to its authenticated legal endpoint rather than accepting an exchange-generated label as determinative. The framework was developed against primary authority across the full contract lifecycle, testing Section 1256 and option status, Sections 1234 and 1234A, capital asset and sale or exchange requirements, wagering treatment under Section 165(d), and basis and loss allowance. Business status was tested separately from dealer, inventory, and mark-to-market status. The analysis then carried through to the partnership and its members, covering allocations across the midyear ownership changes, capital accounts, member compensation, self-employment and net investment income tax, software development expenditures, and multi-state exposure.
The Outcome
The firm holds a coordinated package of federal and taxpayer-capacity opinions, a partnership and member-level planning memorandum, the supporting evidence workpapers, and a schedule of outstanding information tied to the calculations and filings that depend on it. Positions are classified by contract category and legal endpoint under a documented method, with verified conclusions separated from management representations and unresolved items throughout.