When a listed or unlisted call is exercised and the writer thereof is called on to sell the underlying stock, the writer adds the amount of the option “premium” received for writing the call to the total strike price to determine the total amount realized on the sale. Then, to the extent that the total amount realized exceeds the writer’s tax basis in the stock sold, he or she realizes a capital gain; if the writer’s tax basis exceeds the total amount realized, he or she has a capital loss. (See Q
702 for the treatment of capital gains and losses.) The nature of such gain or loss generally depends on the holding period of the stock sold (see Q
699 and Q
702), regardless of the time the “call” was outstanding.
1
If an investor writes a call option as part of an overall tax straddle, the tax straddle rules may result in deferring recognition of a loss realized on the exercise of the call option and, in addition, may have unfavorable effects on the characterization of gains and losses realized on positions making up the straddle.
See Q
7593 to Q
7614 for details.
It is unclear whether the writer of a call will be deemed to have entered into a contract to sell the underlying property, within the meaning of IRC Section 1258(c)(2). For more on conversion transactions,
see Q
7615 and Q
7616.
See Q
7594 for an explanation of the rules governing covered call options.
1. Rev. Rul. 78-182, 1978-1 CB 265.