lnofeisone

PTON starter paired with a sale of a covered call.

I, too, was born in USSR in the early 80s and I can attest to many of these things. My opinions has been slowly evolving (not in a very favorable direction), especially as I look back. I read Solzhenitsyn few years after USSR collapsed and didn't really appreciate what I was reading. I have since re-read his works in the US and always have bits and pieces that always float to the top of the memory heap. I now fully appreciate how corruption was endemic and Government was beyond f*ed up. I got few stories that evolved from a fond memory to realization that things weren't great. I thought I had a great childhood, was free to do a lot, had (relatively) successful parents. I grew up in Uzbekistan so fruit/vegetables were not an issue but all other things were. Toilet paper was a commodity, meat, clothing, shoes!!!! were a luxury. COVID really reminded me of a few things. Who knew my childhood training of waiting in line (I always loved being in a milk or breadline because of the gossip) and buying bulk would come in handy. My wife was looking at it me like "wtf are you doing" but that opinion changed as Costco ran out of toilet paper and paper towels. My mom was an engineer at an electric factory so I got to spend a lot of time in the warehouse counting nuts, bolts, and other components. Whenever we would go to a local bazaar we would run into my mother's coworkers selling stuff. I always thought it was curious that my mom's factory had electric components and these individuals were selling these same components...when I was about 12, I figured it out. One thing that goes somewhat unnoticed is the forced labor component of the USSR (this perpetuated well beyond the USSR). Between ages of 5-8, every April/May my mom's factory would organize these buses to go and pick cotton. I was little so I was pumped being outside with other kids and we would race each other collecting cotton. I always wondered why the adults were so slow at gathering it. It's obvious now. There were other things, like cleaning school grounds, collecting paper, collecting metal. I never disliked it because it was me hanging out with my friends but in retrospect it doesn't look great. Dinar reminded me of the cannon fodder. Army was cannon fodder (it was a common russian phrase too, pushechnoe myaso). My dad was an army surgeon stationed in Herat, Kunduz, and later Termez during Afghan war. I still remember asking him to tell me the difference between basmachi (afghan uprising of 1930s) and dushmani (the 80s iteration of the rebels). I didn't have to worry about the army service in Afghanistan because USSR withdrew already but both my parents would make sure I studied hard and gave bribes (I had to carry these gifts to school too!) to my teachers just in case I didn't score well. Drugs and alcohol consumption was out of this world. Everyone would community shame these individuals. Alcohol consumption was at every level. Drug consumption would frequently be amongst the young people, often coming back from Afghanistan. The cancel culture is scary and very reminiscent of some of the Dostoevsky's writing. Sure, you won't go to prison for holding an opposing opinion but you can easily be shut out of the job. I noticed many of my staff now self sensor themselves. The days of open fora have disappeared. I live in DC so all we have is very loud hell-bent liberal (what I hope) minority. I've been to places where the opposite is true. I sure hope that the silent majority still hasn't lost common sense and maintains it's centrist POV.

I think you hit the nail on the head that these loans take a while and the process is a bit opaque so not particularly favorable in a bidding process. I did see a lot of 232s coming though for specialized nursing and senior housing but I can't recall if ever saw the likes of Ventas in the mix (though I wasn't really paying attention to that).

@LearningMachine These loans (guaranteed by Ginnie) have to be through one of the Gov't programs (e.g., FHA, USDA, PIH, VA) so the housing has to roll up to one of these. Someone like AVB wouldn't be able to use these programs to purchase MF housing. I view this as somewhat of a niche area of the mortgage market. If you google Greystone or Walker Dunlop and see most recent deal flow, you'll get the sense of who takes advantage of these programs (232, 223f, etc.). Wells Fargo is a reasonably large player here as well. FHA loans will come with 1% upfront + annual insurance of up to 0.6%. @thepupil - the 40 year option just went live nowish (December?). The loans you funded must've been mighty recent. For those interested this product would go into a a custom pool (designated C-ET [custom extended]) with a single mortgage with a min balance of at least 25k.

I'd also be interested. Looking at TCNNF.

In this instance, the 10k is within the 15k you are permitted to give tax free every year. You also have a lifetime gift exemption so there are way easier ways to optimize taxes here. If you want to get creative with taxes (you basically want to avoid getting hit with the kiddie tax.), the loophole here is to give the 10k that is assigned to the adult to the child right after you buy it. I bonds have a provision that when you gift/change owners, you must pay tax on any accrued interest. If you gift it right after you buy it, there will be minimal accrual of interest. The taxes for the child will look like this - the first $1.1k of interest (I think that's the current number) is a standard deduction. The next $1.1k will be taxed at kid's tax rate - if child has no income it is 0. After that, any interest will be taxed at adult's marginal rate.

Selling my puts. Accidental multi-bagger.

Some of these are algorithms but some of these are whole domains, e.g., Neural Networks, and on their own won't get you very far. Most of the algos listed are a good theoretical/academic start but have been proven to work well in a limited set of domains. To further complicate things, any respectable shop will have pipelines with 10,000+ models at any given time. The recent R&D from NVIDIA, MSFT, Google take neural networks (GANs) to entirely new level. Just take a look at NVIDIA Riva SDK (anyone remembers Riva GPU from the 90s!; the two are not related other than both being from NVIDIA). Google's BERT and T5 fall into the same category. There is a massive push to combine AI with more domain specific knowledge (think spectral analysis for voice, etc.) to get good results.

That's the only thing I found. Though looking at their schedules, 2022 is going to be bumpy. The management is conservative and has been shareholder friendly in the past so it's worth to me buying some here. I should note that this has been one of those trades I've been doing over the years. Buy sub-15, sell at 20.

Starter in KNOP. Will probably go to 50% of position if it hits 10.

This is why Weapons of Math Destructions by Cathy O'Neil has been a mandatory read for students in my class since the day the book was published. It's an easy read that gives a glimpse what bad automation can look like. I do agree that AI will permeate every aspect of our lives. What I find interesting is AI is entrenching in low and high value tasks almost simultaneously. Low end of the spectrum makes money on volume (think forms processing). High end makes $ on complexity (think Tesla CV system). Ends users are generally oblivious to what is happening and user adoption is consistently high. Implementation costs is what varies. On a personal note, I'm very well versed in graph and NLP spaces. I can't wait for Neo4j to IPO. Further maturation of NLP will be big too (moving beyond BERT and T5).

MSGE, VZ, DIS starters.

18s.

Sold/selling Jan 23 ATUS puts.

I thought this was a fascinating read: https://palladiummag.com/2021/10/11/the-triumph-and-terror-of-wang-huning/ "Instead, they see Wang’s America: deindustrialization, rural decay, over-financialization, out of control asset prices, and the emergence of a self-perpetuating rentier elite; powerful tech monopolies able to crush any upstart competitors operating effectively beyond the scope of government; immense economic inequality, chronic unemployment, addiction, homelessness, and crime; cultural chaos, historical nihilism, family breakdown, and plunging fertility rates; societal despair, spiritual malaise, social isolation, and skyrocketing rates of mental health issues; a loss of national unity and purpose in the face of decadence and barely concealed self-loathing; vast internal divisions, racial tensions, riots, political violence, and a country that increasingly seems close to coming apart."

I originally said deep ITM calls would be needed. That was wrong. ATM or OTM would be the way to go since both would fail the substantially identical test (delta != 1).

Note that there is nothing about you needing to hold your options to expiry. Footnote 62, sheds some light on that ambiguity. What you are highlighting is another way to circumvent the wash sale rule. You can also buy super cheap deep OTM calls that go 31+ days out and bypass the wash rules. In either case, the taxpayer would be trying to gain a tax advantage at no substantial change of economic profile and any regulatory body will not look kindly on it.

Thanks for this well thought out comment. Really adds to the knowledge of the board. I would encourage you to take a look at the article that @hyten1 posted. Scroll to page 25-26. Read the exact strategy I posted. So now you have two respectable sources that point to legal validity of the transaction. At what point do you concede?

Started to buy more serious UNG put positions. Trash security in an overextended natural gas market. I'm also using the cover of the economist as my "do the opposite" proxy.

Yes, we all have our perceptions. My perception was that your analysis lacked any serious depth, built on preconception that it's a simple issue, and lacking the appreciation of transaction complexities and nuances, backed by a barely a source (yes, fool.com is pop finance and qualifies as barely a source.). I can write all that off as having a discussion on a board but if you are going to pound that table strong, make sure you are not wrong. I assure you, you were not right. Trying to somehow change the subject and insinuate (borderline insult?) that I don't know what covered calls are is, both, disingenuous and hilarious. You assumed that I am would be gaslighting the IRS with my take on things. Even if we take your elementary understanding of the term "gaslighting" (which, and I'm going to take a leap of faith here, was not part of your vocabulary 10-15 years ago despite the age of the term): 1) Taxpayers have disagreements with IRS all the time. Until 1988, calls were not even considered securities and IRS lost. It's not gaslighting. It's disagreements. This is why we have courts. 2) Gaslighting is typically done by the entity in power. I assure you, I have very limited power over the IRS other than knowing the little realm of my domain down to science. In fact, the power imbalance is the complete opposite. Having said all that, for education purposes, here is a paper by tax partners from Davis Polk (some would say it's a reasonably respectable law firm). Here are their names - Lucy Farr and Michael Farber. Both are current practicing tax partners. So no anonymity of a "Deloitte partner" on some blog on nasdaq.com Take a read to appreciate the history of the wash sales rules, current(ish, circa 2002) issues (e.g., swap), the loop holes that are big enough to drive a dump truck through that are wash sales rules. Most of them untested, unsettled, and inconsistent. That includes that strategy steps that I laid out (not directly but inferred). I am happy to email you a copy if you don't have a subscription. https://heinonline.org/HOL/LandingPage?handle=hein.journals/jrlfin3&div=31&id=&page= 3 J. Tax'n Fin. Products 41 (2002) Dirty Linen: Airing out the Wash Sale Rules Feel free to respond (or not) but please 1) keep it to a source that is not your opinion 2) civil.

Turns out options are not considered securities. In fact, I was pointed to a specific court case where IRS lost because of that. It's a moot point for our discussion because of TAMRA (1988) but so you have it for your reference: "In a Tax Court case, Gantner v. Commissioner (91 T.C. ... denied, 498 U.S. 921 (1990)), the court found that stock options were not securities for purposes of the wash sales rule."

Repeating one last time. If you don't get it, you don't get it. It's fine. 1) Sell your stock at a loss (say you lost $10/share) <--applies to this sale 2) Buy a call option - you can buy a deep in the money call (say, $15). You have now triggered a washsale. Meaning you can't take a loss on your stock but your cost basis for the call has gone up to $25/share. 3) Buy your stock back 4) Sell the call at a loss <-- doesn't apply to this sale Honestly, we are now walking in circles and I'm going to call it a day.

I'm not trolling nor am I saying that options are not securities. What I am pointing you to is the fact that everything in what you posted says "acquire" and the 4th step of what I posted is a sale.

1. Buy substantially identical stock or securities, 2. Acquire substantially identical stock or securities in a fully taxable trade, 3. Acquire a contract or option to buy substantially identical stock or securities, or 4. Acquire substantially identical stock for your individual retirement arrangement (IRA) or Roth IRA. The issue is not stock or securities. Step 4 is a sale of a call so no it doesn't. There is nothing here about sale of a stock/call/security. Anyway, how about we close this one. There is no $ to be made here. This is a legally valid strategy to bypass wash sale but an impermissible transaction (as aws said "substance over form") because you are reaping a tax benefit without changing an economic profile (I did tell you early on that this violates the spirit of the law). Any revenue agent worth their salt will call it as that (though I do wonder if they would see something like this if you just give a sheet of all the transactions).