Although the definition of a foreign currency contract provided in 1256(g)(2) may be read to include a foreign currency option contract
, the legislative history of the Technical Corrections Act of 1982, which amended 1256 to include foreign currency contracts, indicates that the Congress intended to extend [section] 1256 treatment only to foreign currency forward contracts that are traded on the interbank market.
Mylan has provided adjusted diluted cash EPS which excludes amortization expense, including that related to the acquisition of Matrix, and a gain on a deal-contingent foreign currency option contract which was entered into in order to mitigate foreign currency risk associated with the Euro-denominated purchase price related to the acquisition of Merck KGaA's generic business ("Merck Generics").
5 million related to the Company's deal-contingent foreign currency option contract related to the Merck Generics acquisition, as well as an increase in interest and dividend income.
At December 31, 1998, Telewest's significant financial instruments include cash and cash equivalents, trade receivables, a foreign currency option contract, the Foreign Currency Swap, the Interest Rate Swaps, the Foreign Exchange Forward Contracts, the Interest Rate Cap, trade payables and long-term borrowings.
Telewest may be exposed to potential losses due to the credit risk of non-performance by the counterparties to its Foreign Currency Swap, Interest Rate Swaps, the Foreign Exchange Forward Contracts and the foreign currency option contract, however such losses are not anticipated as these counterparties are major international financial institutions.
The petitioner, Michael Napoliello, entered into two pairs of offsetting long and short foreign currency option contracts
held by an LLC of which he was the sole member.