Special Dividends: "Due Bill" Process
In some cases, special dividends may have different rules than regular dividends concerning the ex-dividend date. If a special dividend is less than 25% of the stock price, standard rules apply regarding the ex-dividend date (ex-date is before the record and pay date). However, if a special dividend is greater than 25% of the stock price*, the ex-dividend date will be after the record date and pay date.
In the case of a regular dividend or a special dividend of less than 25% of the share price, one would need to own a stock by the record date in order to be entitled to the dividend. However, this is not the case for special dividends that are more than 25% of the stock price. If one were to sell a stock after the record date but before the ex-dividend date, they would no longer be entitled to the dividend. The shares would be tagged with something called a "due bill" which means that the seller is obligated to pay the dividend to the buyer. Likewise, if one were to buy a stock after the record date but before the ex-dividend date (and hold it through the ex-date), they would be entitled to the dividend from the seller.
*Please note, the 25% or more rule is a general rule and will not apply in all cases. Certain foreign stock dividends will not follow the rule and some domestic stocks are granted an exclusion. For information regarding regular dividends, please reference KB 47.
Withholding Tax on Dividend Equivalent Payments - FAQs
Background
Beginning January 1, 2017, new IRS regulations will impose U.S. withholding taxes on US dividend equivalent payments to non-US persons holding derivative positions on US equities. Previously, US withholding tax was not imposed on these payments. The regulations require intermediaries, such as us, to act as withholding agents and collect US tax on behalf of the IRS. An overview of the tax, how it’s determined and the products impacted is provided below.
Overview
What is the purpose of the regulation?
The regulation derives from Section 871(m) of the Internal Revenue Code and is intended to harmonize the US tax treatment imposed on non-U.S. persons with respect to dividends on U.S. stock and dividend equivalent payments paid on derivative contracts that replicate (to a high degree) ownership of such stock.
An example of this would be a total return swap having IBM as its underlying. A non-U.S. person holding an IBM stock position would be subject to a 30% US withholding tax (reduced by treaty) on dividend payments. On the other hand prior to the implementation of Section 871(m), a non-U.S. person holding long exposure to IBM on the swap could receive payments equivalent to the dividends without imposition of U.S. withholding tax. This was the case even though the payments replicated similar economic exposure. Section 871(m) now considers those ‘dividend equivalent payments’ subject to US withholding tax.
What is a dividend equivalent payment?
A dividend equivalent payment is any gross amount that references the payment of a dividend on a U.S. equity and that is used to compute any net amount transferred to or from the long party, even if the long party make a net payment to the short party or the net payment is zero. Accordingly, such payments would include not only an actual payment in lieu of a dividend but also an estimated dividend payment that is implicitly taken into account in computing one or more of the terms of the transaction, including interest rate, notional amount or purchase price.
In the case of a listed call option on a U.S. stock, for example, the holder of the call is not entitled to receive a dividend unless the option is exercised prior to the dividend ex-date. Nonetheless, the premium paid by the holder to purchase the option implicitly takes into account the present value of the expected dividends over the option term.[1] Since this factor serves to lower the payment from the option buyer to the seller, it is viewed as a dividend equivalent payment potentially subject to the rules.
Who is subject to the dividend equivalent withholding tax?
The tax applies to qualifying positions held in an account of a non-U.S. taxpayer. It does not apply to U.S. taxpayers. Accounts of non-U.S. taxpayers generally are evidenced by the submission of an IRS Form W-8 and can include the following account types: individual, joint, organization and trust.
What derivative instruments potentially are subject to the dividend equivalent withholding tax?
The regulations adopt a two-part test to determine if a derivative instrument is subject to the rules. First, the derivative instruments must reference the dividend on a U.S. equity security. Examples include:
- equity options
- regulated single stock futures
- regulated index futures and options on index futures
- structured and exchange traded notes
- CFD contracts
- convertible bonds
- securities lending transactions
- derivatives on custom baskets and
- warrants
If the underlying position is a U.S. equity. The exchange upon which the instrument is traded and the identity of the counterparty do not affect the application of the rules. That is, a derivative can be subject to the rules, whether it is exchange listed or over the counter or trades in the United States or overseas.
Second, the derivative instrument must substantially replicate the economics of the underlying U.S. equity at the time of issuance. The rules look to delta (for simple contracts) and a substantially equivalency test (for complex contracts) to make this determination.
Delta is a correlation measurement that computes the ratio of the change in the fair market value of the derivative instrument to a change in the fair market value of the U.S. equity referenced by the derivative. In general, for purposes of this regulation, delta is only determined once over the life of the derivative instrument – at the time it is ‘issued’. It is not recomputed as the fair market value of the underlying security changes or when the derivative instrument is re-sold in the secondary market.
For most contracts, the rules are as follows:
· Pre-2017 – a derivative instrument issued prior to January 1, 2017 (i.e., anything held by a customer with us on December 31, 2016) is not subject to the new withholding tax rules.
· 2017 - a derivative instrument issued in 2017 is potentially subject to the new withholding tax regime if the delta at the time of issuance is 1.0.
· After 2017 – a derivative instrument issued after December 31, 2017 is potentially subject to the new withholding tax rules if the delta at the time of issuance is 0.8 or greater.
If the derivative is classified as “complex,” the delta test does not apply and instead the substantial equivalency test applies.
So When Is a Derivative Instrument Issued?
Identified when a derivative instrument is issued is very important. It determines if the instrument is subject to the rules (pre-2017 issued instruments are not) and when the delta computation is made. In general, an instrument is ‘issued’ when it comes into existence, its inception date or date of original issuance. Instruments are not issued when re-sold in the secondary market.
As a result, there are differences in the issuance rules for listed options, futures, other exchange traded products and over-the-counter products. For example, a listed option traded on a US exchange, generally, is not issued when first listed by an exchange as available for trading. Instead, the listed option is issued (delta determined) when the option is entered into by the customer. On the other hand, for transferable derivatives, such as exchange traded notes, convertible bonds and warrants, they would be issued only when first sold. The delta determined at that time would carryover when sold to a subsequent purchaser.
Are There Any Exceptions?
The rules do provide limited exceptions to withholding. These include:
• a derivative instrument that references a “qualified index” - generally, a passive broad publicly available index on U.S. equities such as the S&P 500, NASDAQ 100 or Russell 2000.
• a derivative instrument that references an index with little or no U.S. equity composition – such as the Hang Seng Index.
• if the dividend equivalent payment (or portion thereof) would not be subject to U.S. withholding tax if the non-US person owned the underlying security directly. This most often will occur for derivative instruments on U.S. mutual funds, REITs and exchange traded funds that pay ‘dividends’ which are re-characterized as capital gain distributions or returns of capital.
Can you provide some examples of when the rules will or will not apply?
• Customer purchases single stock futures on IBM on January 2, 2017. The delta of the future is 1.0. The future is subject to the rule.
• Customer purchases a deep in the money OCC listed option on IBM on December 28, 2016. The delta of the future is 1.0. The option is not subject to the rule as it was issued prior to 2017.
• Customer purchases index future on a narrow based index on January 15, 2017. Assume the index is not a ‘qualified index.’ The future is subject to the rule.
• Customer purchases an exchange trade note that tracks U.S. equities on January 2, 2017 with a delta of 1.0. The note was issued on July 1, 2016. The option is not subject to the rule as it was issued prior to 2017
How is the dividend equivalent withholding computed?
If the derivative instrument is subject to the new Section 871(m), a dividend equivalent payment with respect to such instrument equals the per share dividend on the underlying U.S. equity, multiplied by the number of underlying shares referenced by the instrument, multiplied by the delta (e.g., an option contract delivering 100 shares of a stock paying $1.00 dividend and having a delta of .80 would be subject to a tax based upon $80.00 dividend equivalent payment).
In the case of a complex derivative contract, the dividend equivalent will be equal to the per share dividend on the underlying, multiplied by the contract’s hedge equivalent to the underlying as calculated when the contract was issued.
How are contracts combined for purposes of determining delta?
Starting in 2018, customers who purchase derivative instrument such as a long call having a delta below the .80 threshold and selling a put on the same underlying and same share quantity within 2 days of one another will have those positions combined for the purpose of determining whether the threshold has been exceeded (e.g., the purchase of a long call with a delta of 0.60 coupled with the sale of a put with a delta of .40 would result in a long delta of 1.0).
In 2017, only over-the-counter instruments are potentially subject to combination to create a delta 1.0 instrument.
What information do we provide to inform clients about impacted positions?
To minimize exposure to the withholding tax, we intend to provide a TWS warning message will be provided when non-U.S. persons create an order that could generate the tax. This will give customers the option of canceling the order to avoid potential withholding or submitting the order and possibly paying the tax when a dividend occurs. Customers may avoid the potential withholding tax by not owning the derivative on the applicable withholding date (i.e., generally the dividend Record Date).
IMPORTANT NOTE: We do not provide tax, legal or financial advice. Each customer must speak with the customer’s own advisors to determine the impact that the Section 871(m) rules may have on the customer’s trading activity.
[1] While the holder of the call option does not receive a dividend, the premium paid by the holder for the option implicitly takes expected dividends into account (i.e., because the stock price is expected to drop by the amount of the dividend on the ex-dividend date, cash dividends imply lower call premiums).
Dividend Accruals
If you are a shareholder of record as of the close of business on a dividend Record Date (see KB47), you are entitled to receive the dividend on its Payment Date. While the actual dividend amount is not assured until the payment has been made by the issuer on the Payment Date, information deemed reliable is available such that IB will accrue the value of the dividend, net of any withholding taxes, on the Ex-Date. This information can be confirmed via the Daily Activity Statement posted to Account Management. The details of the accrual will be reflected in the statement section titled "Change in Dividend Accruals" and the net amount in a line item titled "Dividend Accruals" under the "Net Asset Value" section. If you wish to see information regarding dividends that you held through the Ex Date but which have not yet been paid out, choose "Legacy Full" from the Statements drop down when launching your statement. This will include an additional section called "Open Dividend Accruals" which will give you information on any pending dividends.
Note that dividend accruals may be either a debit (if short and borrowing the stock on the Record Date) or a credit (if long the stock on the Record date). In terms of account valuation, the dividend accrual is included in Equity with Loan Value as well as equity for purposes of determining compliance with the Pattern day Trading rules. A dividend credit accrual does not increase Available Funds and can therefore not be withdrawn until paid. A dividend accrual which is a debit does reduce Available Funds to ensure that funds are available to meet the obligation when payment is due.
Overview of IBKR's Dividend Reinvestment Program (DRIP)
IBKR offers a dividend reinvestment program whereby accountholders may elect to reinvest qualifying cash dividends to purchase shares in the issuing company. Outlined below are a series of FAQs which describe the program and its operation.
1. How can I participate in the program?
Requests to participate are initiated online via Client Portal. The menu options vary by account type and are outlined below:
• Individual, Joint, Trust, IRA, Small Business Accounts – click on the User menu (head and shoulders icon in the top right corner) followed by Settings. Under Trading, click Dividend Election where you can enable the program. Read the agreement, type your signature in the field provided and click Subscribe.
• Advisor and Broker Master and Proprietary Trading Group STL Master Users – Select the Contacts tab from the Dashboard on the Home page. Click the Information icon “I” for the desired client account or service account to open the Client Account Details page. Enable dividend reinvestment by clicking the Edit link in the Account Configuration section.
Once enabled, you’ll be provided with an acknowledgement requiring entry of your electronic signature in order to click the Continue button. Automatic dividend reinvestment will be effective the next business day.
2. What accounts are eligible to participate in IBKR's Dividend Reinvestment Program?
Dividend Reinvestment is available to IB LLC, IB AU, IB CAN, IB HK, IB IE, IB JP, IB SG and IB UK clients only.
3. Which securities are eligible for dividend reinvestment?
Only U.S. and Canada-listed common and preferred stocks paying cash dividends are eligible for reinvestment.
4. When does reinvestment occur?
If you are a shareholder of record as of the close of the dividend record date (see KB47) and enrolled in the dividend reinvestment program prior to the dividend payment date, IBKR will use the dividend payment to purchase additional shares of that stock on the morning of the trading day which follows confirmation of our receipt of the dividend. For accounts with AutoFX enabled, when the DRIP system runs that what-if credit check, the Credit Manager will now consider the cash balances across all the currencies the account has, allowing for FX to be booked to fund the DRIP trade if needed. If a customer's credit-check fails on the day dividend was paid, the system continues to check for the next 30 days and may include it in the DRIP file when the credit-check passes. In this case the system may book a delayed DRIP trade (i.e. trade date after paydate). IBKR will also look back 30 days from the date of enrollment and will reinvest any dividends paid to the account within that 30 day time period. Note that shares are not purchased via an issuer-sponsored reinvestment plan but rather in the open market.
5. At what price does reinvestment take place?
As shares are purchased in the open market, generally at or near the opening of trading and subject to market conditions, the price cannot determined until the total number of shares for all program participants have been purchased using combined funds. In the event that the purchase is executed in multiple smaller trades at varying prices, participants will receive the weighted-average price of such shares (i.e., each participant receives the same price). In the event IBKR is unable to reinvest the combined proceeds, each participant will receive shares on a pro rata basis (based on the dividend amount to which each participating client is entitled).
6. Are the full proceeds of the cash dividend available for reinvestment?
No. Only the proceeds net of commissions and taxes (if the account is subject to withholding) is reinvested.
7. Are dividends from shares purchased on margin and loaned by IBKR eligible for reinvestment?
Yes. If IBKR maintains a lien on shares as a result of a margin loan, the account holder will receive a cash payment in lieu of and equal to the dividend payment. This payment in lieu will be used to purchase additional shares of that stock.
8. Are dividends from shares loaned through IBKR’s Yield Enhancement Program eligible for reinvestment?
Yes. While IBKR makes every effort to recall shares loaned through this program prior to the dividend record date, if such shares are not recalled the account holder will receive a cash payment in lieu of and equal to the dividend payment. This payment in lieu will be used to purchase additional shares of that stock.
9. Is the dividend reinvestment subject to a commission charge?
Yes, standard commissions as listed on the IBKR website are applied for the purchase. Please note that the minimum commission charge is the lesser of the stated minimums (USD 1 for the Fixed structure and USD 0.35 for the Tiered structure) or 1% of the trade value.
10. What happens if my account is subject to a margin deficiency when reinvestment occurs?
If your account is in a margin deficit and can’t initiate new positions, dividends will not be reinvested, even if you have dividend reinvestment enabled. Please note that dividend reinvestment orders are credit-checked at the time of entry—should an account go into margin deficiency at any time after that, including as a result of the end-of-day SMA check and the end of Soft Edge Margin, the account will become subject to automated liquidation.
11. Can account holders elect which securities are eligible for reinvestment?
Yes, account holders may elect which securities are eligible for dividend reinvestment.
12. Are fractional shares eligible for the Dividend Reinvestment Program (DRIP)?
Yes, it is possible to receive fractional shares for a reinvested dividend through the Dividend Reinvestment Program (DRIP) as long as the account has fractional share permissions.
13. Does dividend reinvestment cover solely regular cash dividends or are special cash dividends reinvestment as well?
All cash dividends are reinvested.
14. What are the tax considerations associated with dividend reinvestment?
The purchase of a shares via DRIP is similar to that of any other share purchase for purposes of tax reporting. In the case of U.S. taxpayers:
- When the shares purchased via DRIP are sold they will be reported on the Form 1099B for US taxpayers in the year in which they are sold. The gain or loss will be calculated based on the FIFO method unless the account holder has selected a different method. The cost basis will be that price at which the shares were purchased and the acquisition date the date of reinvestment or purchase (not the day the dividend is paid).
- Shares purchased via dividend reinvestment are subject to wash sale calculations (i.e., if you sold a security for a loss within 30 days before or after the purchase, a wash sale will occur and that loss deferred).
- Dividend payments are subject to reporting on the Form 1099DIV as current year income even when reinvested.
In the case of non-U.S. taxpayers:
- The cash dividend is subject to U.S. tax withholding prior to reinvestment. Withholding is performed at the statutory rate or at the treaty rate, where available. All income and withholding will be reported on the Form 1042-S for the year in which the dividend payment was received.
Overview of Dividend Payments in Lieu ("PIL")
Payment In Lieu of a Dividend (“payment in lieu” or “PIL”) is a term commonly used to describe a cash payment to an account in an amount equivalent to the ordinary dividend. Generally, the amount paid is per share owned. In addition, the dividend in most cases is paid quarterly (i.e., four times per year). The dividend payment is classified as follows: (1) ordinary dividend; and/or (2) payment in lieu of dividend. The former designation is for a payment received directly from the issuer or its paying agent. The latter designation is used when a cash payment is received from other than the issuer or the issuer’s agent.
Payment in lieu of an ordinary dividend may be received when the shares have been bought on margin, or when the account has a subsequent margin loan due to borrowing money to facilitate the payment for additional purchases of shares or as the result of a withdrawal from the margin account. Payment in lieu of a dividend may also be received when shares are owed to the brokerage firm and have not been received by the dividend record date.
To better understand the difference between an ordinary dividend and a payment in lieu, we will explain the steps taken by IB to comply with US regulations. Each business day, the Firm analyzes the positions in each customer account, every borrow, every loan, every pledge of shares for each security held by its customers to determine how many shares are held on margin and the associated margin loan balances. For each security that is fully paid, we are required to segregate those shares in a good control location (for example, a depository or a US bank. See KB1964). For shares that are held as collateral for a margin loan we are allowed to hypothecate and re-hypothecate shares valued up to 140 percent of the total debit balance in the customer account (See KB1967).
While the guidelines noted above for segregation of securities are clear, there are exceptions that are outside of the Firm's control. For instance, through no fault of its own, IB may have a deficit in segregated shares due to customer activity that changes the Firm’s overall segregation requirement for a security. This may be for a variety of reasons including a delay in receiving shares that have been loaned out to a counterparty after segregation requirements are recalculated and the Firm has issued a stock loan recall, sales of securities by one or more customers that reduce or eliminate margin loans, the deposit of cash by customers that similarly reduce or eliminate margin loans, or a failure of a counterparty to deliver shares for a trade settlement.
Upon issuing a recall of shares loaned, rules permit the borrower of the shares up to 3 business days to return them. The borrower of the shares is required to return them to us when we issue a recall, but if by business day 3 the shares have not been returned, IB may then issue a buy-in notice to begin the process of regaining possession of the shares. An additional 3 business days is generally needed for the purchased shares to settle and be delivered to the firm. Similarly if a counterparty fails to deliver by settlement date, shares to IB to settle a customer purchase, IB can issue a buy-in notice but the purchase of such shares are also subject to trade settlement in 3 days.
To summarize, if by the record date of a dividend certain shares have not been delivered to IB, the Firm will be paid an amount of cash that is equivalent to the dividend amount, but IB will not receive a qualified dividend payment directly from the issuer. In such cases, the Firm will receive PIL and will have no choice but to allocate such payment in lieu to customer accounts. The firm first allocates PIL to those accounts who hold the shares as collateral for a margin loan. If, after PIL is allocated to all shareholders whose accounts are not fully paid, any portion of PIL remains to be paid, it is allocated on a pro-rata basis to each remaining client account.
Account holders should be aware that a PIL may have different tax consequences than an ordinary dividend and should consult a tax advisor to understand such differences and whether they apply to their particular situation.
Dividend Tax Withholding on Depository Receipts
In the event an account holds a dividend paying depository receipt, at the time of the dividend payment taxes will be withheld. In several jurisdictions, IB is unable to efficiently comply in an electronic, straight-through manner with the required beneficial owner disclosure requirements. As such, dividends on depository receipts where full beneficial owner disclosure is required in order to receive beneficial tax treatment will be withheld at the maximum tax rate applicable.
Shareholders will not be eligible for reduced tax treatment on the allocation of cash through IB. All shareholders should consult their tax advisor for information on how to obtain a tax refund or tax credit for such activity.
Considerations for Exercising Call Options Prior to Expiration
INTRODUCTION
Exercising an equity call option prior to expiration ordinarily provides no economic benefit as:
- It results in a forfeiture of any remaining option time value;
- Requires a greater commitment of capital for the payment or financing of the stock delivery; and
- May expose the option holder to greater risk of loss on the stock relative to the option premium.
Nonetheless, for account holders who have the capacity to meet an increased capital or borrowing requirement and potentially greater downside market risk, it can be economically beneficial to request early exercise of an American Style call option in order to capture an upcoming dividend.
BACKGROUND
As background, the owner of a call option is not entitled to receive a dividend on the underlying stock as this dividend only accrues to the holders of stock as of its dividend Record Date. All other things being equal, the price of the stock should decline by an amount equal to the dividend on the Ex-Dividend date. While option pricing theory suggests that the call price will reflect the discounted value of expected dividends paid throughout its duration, it may decline as well on the Ex-Dividend date. The conditions which make this scenario most likely and the early exercise decision favorable are as follows:
1. The option is deep-in-the-money and has a delta of 100;
2. The option has little or no time value;
3. The dividend is relatively high and its Ex-Date precedes the option expiration date.
EXAMPLES
To illustrate the impact of these conditions upon the early exercise decision, consider an account maintaining a long cash balance of $9,000 and a long call position in hypothetical stock “ABC” having a strike price of $90.00 and time to expiration of 10 days. ABC, currently trading at $100.00, has declared a dividend of $2.00 per share with tomorrow being the Ex-Dividend date. Also assume that the option price and stock price behave similarly and decline by the dividend amount on the Ex-Date.
Here, we will review the exercise decision with the intent of maintaining the 100 share delta position and maximizing total equity using two option price assumptions, one in which the option is selling at parity and another above parity.
SCENARIO 1: Option Price At Parity - $10.00
In the case of an option trading at parity, early exercise will serve to maintain the position delta and avoid the loss of value in long option when the stock trades ex-dividend, to preserve equity. Here the cash proceeds are applied in their entirety to buy the stock at the strike, the option premium is forfeited and the stock (net of dividend) and dividend receivable are credited to the account. If you aim for the same end result by selling the option prior to the Ex-Dividend date and purchasing the stock, remember to factor in commissions/spreads:
| SCENARIO 1 | ||||
|
Account Components |
Beginning Balance |
Early Exercise |
No Action |
Sell Option & Buy Stock |
| Cash | $9,000 | $0 | $9,000 | $0 |
| Option | $1,000 | $0 | $800 | $0 |
| Stock | $0 | $9,800 | $0 | $9,800 |
| Dividend Receivable | $0 | $200 | $0 | $200 |
| Total Equity | $10,000 | $10,000 | $9,800 | $10,000 less commissions/spreads |
SCENARIO 2: Option Price Above Parity - $11.00
In the case of an option trading above parity, early exercise to capture the dividend may not be economically beneficial. In this scenario, early exercise would result in a loss of $100 in option time value, while selling the option and buying the stock, after commissions, may be less beneficial than taking no action. In this scenario, the preferable action would be No Action.
| SCENARIO 2 | ||||
|
Account Components |
Beginning Balance |
Early Exercise |
No Action |
Sell Option & Buy Stock |
| Cash | $9,000 | $0 | $9,000 | $100 |
| Option | $1,100 | $0 | $1,100 | $0 |
| Stock | $0 | $9,800 | $0 | $9,800 |
| Dividend Receivable | $0 | $200 | $0 | $200 |
| Total Equity | $10,100 | $10,000 | $10,100 | $10,100 less commissions/spreads |
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NOTE:
Options have two components that make up their total premium value - intrinsic value and time value. The intrinsic value is the amount by which the option is in-the-money, while the time value represents the possibility that the option could become even more profitable before expiration as the underlying asset price fluctuates while providing protection against adverse moves.
Many options are American-style, which means they can be exercised early, ahead of their expiration date. Early exercise of an option eliminates the remaining time value component from the option's premium, since the option holder loses protection against unfavorable movements in the underlying asset’s price.
This makes early exercise suboptimal in most situations, as the option holder is willingly forfeiting a portion of the option's value.
There are a few specific circumstances where early exercise could make sense, such as:
- For call options on a stock that will pay dividends soon, where the dividend amount exceeds the remaining time value (and only if the exercise will settle on or prior to the record date for the dividend).
- For deep in-the-money options where the time value is negligible compared to the intrinsic value, and the option is expected to drop in value due to interest rate effects (PUTS), or expected stock loan benefits (CALLS).
The first case, exercising an in the money call immediately ahead of a dividend payment, is the most common economically-sensible early exercise. In most cases, it is advisable to hold or sell the option instead of exercising it early, in order to capture the remaining time value. An option should only be exercised early after carefully considering all factors and determining that the benefits of early exercise outweigh the time value being surrendered.
Account holders holding a long call position as part of a spread should pay particular attention to the risks of not exercising the long leg given the likelihood of being assigned on the short leg. Note that the assignment of a short call results in a short stock position and holders of short stock positions as of a dividend Record Date are obligated to pay the dividend to the lender of the shares. In addition, the clearinghouse processing cycle for exercise notices does not accommodate submission of exercise notices in response to assignment.
As example, consider a credit call (bear) spread on the SPDR S&P 500 ETF Trust (SPY) consisting of 100 short contracts in the March '13 $146 strike and 100 long contracts in the March '13 $147 strike. On 3/14/13, with the SPY Trust declared a dividend of $0.69372 per share, payable 4/30/13 to shareholders of record as of 3/19/13. Given the 3 business day settlement time frame for U.S. stocks, one would have had to buy the stock or exercise the call no later than 3/14/13 in order receive the dividend, as the next day the stock began trading Ex-Dividend.
On 3/14/13, with one trading day left prior to expiration, the two option contracts traded at parity, suggesting maximum risk of $100 per contract or $10,000 on the 100 contract position. However, the failure to exercise the long contract in order to capture the dividend and protect against the likely assignment on the short contracts by others seeking the dividend created an additional risk of $67.372 per contract or $6,737.20 on the position representing the dividend obligation were all short calls assigned. As reflected on the table below, had the short option leg not been assigned, the maximum risk when the final contract settlement prices were determined on 3/15/13 would have remained at $100 per contract.
| Date | SPY Close | March '13 $146 Call | March '13 $147 Call |
| March 14, 2013 | $156.73 | $10.73 | $9.83 |
| March 15, 2013 | $155.83 | $9.73 | $8.83 |
Please note that if your account is subject to tax withholding requirements of the US Treasure rule 871(m), it may be beneficial to close a long option position before the ex-dividend date and re-open the position after ex-dividend.
For information regarding how to submit an early exercise notice please click here.
The above article is provided for information purposes only as is not intended as a recommendation, trading advice nor does it constitute a conclusion that early exercise will be successful or appropriate for all customers or trades. Account holders should consult with a tax specialist to determine what, if any, tax consequences may result from early exercise and should pay particular attention to the potential risks of substituting a long option position with a long stock position.
SPY - Dividend Recognition
Unlike the case of a stock, in which a dividend is taxable in the year in which it is paid, the SPDR S&P 500 ETF Trust (Symbol: SPY) represents itself as a Regulated Investment Company and its dividend is deemed taxable in the year in which the record date is determined. As such, SPY dividends declared in either October, November or December and payable to shareholders of record on a specified date in one of those months will be considered taxable income income in that year despite the fact that such dividend will generally be paid in January of the following year.
Circular 230 Notice: These statements are provided for information purposes only, are not intended to constitute tax advice which may be relied upon to avoid penalties under any federal, state, local or other tax statutes or regulations, and do not resolve any tax issues in your favor.
Overview of IBKR issued Share CFDs
The following article is intended to provide a general introduction to share-based Contracts for Differences (CFDs) issued by IBKR.
For Information on IBKR Index CFDs click here. For Forex CFDs click here. For Precious Metals click here.
Topics covered are as follows:
I. CFD Definition
II. Comparison Between CFDs and Underlying Shares
III. CFD Tax and Margin Advantage
IV. US ETFs
V. CFD Resources
VI. Frequently Asked Questions
Risk Warning
CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage.
61% of retail investor accounts lose money when trading CFDs with IBKR.
You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.
ESMA Rules for CFDs (Retail Clients of IBKRs European entities, including so-called F segments)
The European Securities and Markets Authority (ESMA) has enacted new CFD rules effective 1st August 2018.
The rules include: 1) leverage limits on the opening of a CFD position; 2) a margin close out rule on a per account basis; and 3) negative balance protection on a per account basis.
The ESMA Decision is only applicable to retail clients. Professional clients are unaffected.
Please refer to the following articles for more detail:
ESMA CFD Rules Implementation at IBKR (UK) and IBKR LLC
ESMA CFD Rules Implementation at IBIE and IBCE
I. Overview
IBKR CFDs are OTC contracts which deliver the return of the underlying stock, including dividends and corporate actions (read more about CFD corporate actions).
Said differently, it is an agreement between the buyer (you) and IBKR to exchange the difference in the current value of a share, and its value at a future time. If you hold a long position and the difference is positive, IBKR pays you. If it is negative, you pay IBKR.
Our Share CFDs offer Direct Market Access (DMA). Our Share CFD quotes are identical to the Smart-routed quotes for shares that you can observe in the Trader Workstation. Similar to shares, your non-marketable (i.e. limit) orders have the underlying hedge directly represented on the deep book of those exchanges at which it trades. This also means that you can place orders to buy the CFD at the underlying bid and sell at the offer.
To compare IBKR’s transparent CFD model to others available in the market please see our Overview of CFD Market Models.
We currently offer approximately 8500 Share CFDs covering the principal markets in the US, Europe and Asia. Eligible shares have minimum market capitalization of USD 500 million and median daily trading value of at least USD 600 thousand. Please see CFD Product Listings for more detail.
Most order types are available for CFDs, including auction orders and IBKR Algos.
CFDs on US share can also be traded during extended exchange hours and overnight. Other CFDs are traded during regular hours.
II. Comparison Between CFDs and Underlying Shares
Depending on your trading objectives and trading style, CFDs offer a number of advantages compared to stocks, but also some disadvantages:
| BENEFITS of IBKR CFDs | DRAWBACKS of IBKR CFDs |
|---|---|
| No stamp duty or financial transaction tax (UK, France, Belgium, Spain) | No ownership rights |
| Generally lower margin rates than shares* | Complex corporate actions may not always be exactly replicable |
| Tax treaty rates for dividends without need for reclaim | Taxation of gains may differ from shares (please consult your tax advisor) |
| Exemption from day trading rules | |
| US ETFs tradable as CFDs** |
*IB LLC and IB-UK accounts.
**EEA area clients cannot trade US ETFs directly, as they do not publish KIDs.
III. CFD Tax and Margin Advantage
Where stamp duty or financial transaction tax is applied, currently in the UK (0.5%), France (0.3%), Belgium (0.35%) and Spain (0.2%), it has a substantially detrimental impact on returns, particular in an active trading strategy. The taxes are levied on buy-trades, so each time you open a long, or close a short position, you will incur tax at the rates described above.
The amount of available leverage also significantly impacts returns. For European IBKR entities, margin requirements are risk-based for both stocks and CFDs, and therefore generally the same. IB-UK and IB LLC accounts however are subject to Reg T requirements, which limit available leverage to 2:1 for positions held overnight.
To illustrate, let's assume that you have 20,000 to invest and wish to leverage your investment fully. Let's also assume that you hold your positions overnight and that you trade in and out of positions 5 times in a month.
Let's finally assume that your strategy is successful and that you have earned a 5% return on your gross (fully leveraged) investment.
The table below shows the calculation in detail for a UK security. The calculations for France, Belgium and Spain are identical, except for the tax rates applied.
| UK CFD | UK Stock | UK Stock | |
|---|---|---|---|
| All Entities |
EU Account
|
IB LLC or IBUK Acct
|
|
| Tax Rate | 0% | 0.50% | 0.50% |
| Tax Basis | N/A | Buy Orders | Buy Orders |
| # of Round trips | 5 | 5 | 5 |
| Commission rate | 0.05% | 0.05% | 0.05% |
| Overnight Margin | 20% | 20% | 50% |
| Financing Rate | 1.508% | 1.508% | 1.508% |
| Days Held | 30 | 30 | 30 |
| Gross Rate of Return | 5% | 5% | 5% |
| Investment | 100,000 | 100,000 | 40,000 |
| Amount Financed | 100,000 | 80,000 | 20,000 |
| Own Capital | 20,000 | 20,000 | 20,000 |
| Tax on Purchase | 0.00 | 2,500.00 | 1,000.00 |
| Round-trip Commissions | 500.00 | 500.00 | 200.00 |
| Financing | 123.95 | 99.16 | 24.79 |
| Total Costs | 623.95 | 3099.16 | 1224.79 |
| Gross Return | 5,000 | 5,000 | 2,000 |
| Return after Costs | 4,376.05 | 1,900.84 | 775.21 |
| Difference | -57% | -82% |
The following table summarizes the reduction in return for a stock investment, by country where tax is applied, compared to a CFD investment, given the above assumptions.
| Stock Return vs cfD | Tax Rate | EU Account | IB LLC or IBUK Acct |
|---|---|---|---|
| UK | 0.50% | -57% | -82% |
| France | 0.30% | -34% | -73% |
| Belgium | 0.35% | -39% | -75% |
| Spain | 0.20% | -22% | -69% |
IV. US ETFs
EEA area residents who are retail investors must be provided with a key information document (KID) for all investment products. US ETF issuers do not generally provide KIDs, and US ETFs are therefore not available to EEA retail investors.
CFDs on such ETFs are permitted however, as they are derivatives for which KIDs are available.
Like for all share CFDs, the reference price for CFDs on ETFs is the exchange-quoted, SMART-routed price of the underlying ETF, ensuring economics that are identical to trading the underlying ETF.
V. Extended and Overnight Hours
US CFDs can be traded from 04:00 to 20:00EST, and the again overnight from 20:00 to 03:30 the following day. Trades in the overnight session are attributed to the day when the session ends, even if a trade is entered before midnight the previous day. This has implications for corporate actions and financing.
Trades entered before midnight on the day before ex-date will not have a dividend entitlement. Trades before midnight will settle as if they had been traded the following day, delaying the start of financing.
VI. CFD Resources
Below are some useful links with more detailed information on IBKR’s CFD offering:
The following video tutorial is also available:
How to Place a CFD Trade on the Trader Workstation
VII. Frequently Asked Questions
What Stocks are available as CFDs?
Large and Mid-Cap stocks in the US, Western Europe, Nordic and Japan. Liquid Small Cap stocks are also available in many markets. Please see CFD Product Listings for more detail. More countries will be added in the near future.
Do you have CFDs on other asset classes?
Yes. Please see IBKR Index CFDs - Facts and Q&A, Forex CFDs - Facts and Q&A and Metals CFDs - Facts and Q&A.
How do you determine your Share CFD quotes?
IBKR CFD quotes are identical to the Smart routed quotes for the underlying share. IBKR does not widen the spread or hold positions against you. To learn more please go to Overview of CFD Market Models.
Can I see my limit orders reflected on the exchange?
Yes. IBKR offers Direct market Access (DMA) whereby your non-marketable (i.e. limit) orders have the underlying hedges directly represented on the deep books of the exchanges on which they trade. This also means that you can place orders to buy the CFD at the underlying bid and sell at the offer. In addition, you may also receive price improvement if another client's order crosses yours at a better price than is available on public markets.
How do you determine margins for Share CFDs?
IBKR establishes risk-based margin requirements based on the historical volatility of each underlying share. The minimum margin is 10%, making CFDs more margin-efficient than trading the underlying share in many cases. Retail investors are subject to additional margin requirements mandated by the European regulators. There are no portfolio off-sets between individual CFD positions or between CFDs and exposures to the underlying share. Concentrated positions and very large positions may be subject to additional margin. Please refer to CFD Margin Requirements for more detail.
Are short Share CFDs subject to forced buy-in?
Yes. In the event the underlying stock becomes difficult or impossible to borrow, the holder of the short CFD position may become subject to buy-in.
How do you handle dividends and corporate actions?
IBKR will generally reflect the economic effect of the corporate action for CFD holders as if they had been holding the underlying security. Dividends are reflected as cash adjustments, while other actions may be reflected through either cash or position adjustments, or both. For example, where the corporate action results in a change of the number of shares (e.g. stock-split, reverse stock split), the number of CFDs will be adjusted accordingly. Where the action results in a new entity with listed shares, and IBKR decides to offer these as CFDs, then new long or short positions will be created in the appropriate amount. For an overview please CFD Corporate Actions.
*Please note that in some cases it may not be possible to accurately adjust the CFD for a complex corporate action such as some mergers. In these cases IBKR may terminate the CFD prior to the ex-date.
Can anyone trade IBKR CFDs?
All clients can trade IBKR CFDs, except residents of the USA, Canada, Hong Kong, New Zealand and Israel. There are no exemptions based on investor type to the residency based exclusions.
What do I need to do to start trading CFDs with IBKR?
You need to set up trading permission for CFDs in Client Portal, and agree to the relevant disclosures. If your account is with IBKR (UK) or with IBKR LLC, IBKR will then set up a new account segment (identified with your existing account number plus the suffix “F”). Once the set-up is confirmed you can begin to trade. You do not need to fund the F-account separately, funds will be automatically transferred to meet CFD initial margin requirements from your main account.
If your account is with another IBKR entity, only the permission is required; an additional account segment is not necessary.
Are there any market data requirements?
The market data for IBKR Share CFDs is the market data for the underlying shares. It is therefore necessary to have market data permissions for the relevant exchanges. If you already have market data permissions for an exchange for trading the shares, you do not need to do anything. If you want to trade CFDs on an exchange for which you do not currently have market data permissions, you can set up the permissions in the same way as you would if you planned to trade the underlying shares.
How are my CFD trades and positions reflected in my statements?
If you are a client of IBKR (U.K.) or IBKR LLC, your CFD positions are held in a separate account segment identified by your primary account number with the suffix “F”. You can choose to view Activity Statements for the F-segment either separately or consolidated with your main account. You can make the choice in the statement window in Client Portal.
If you are a client of other IBKR entities, there is no separate segment. You can view your positions normally alongside your non-CFD positions.
Can I transfer in CFD positions from another broker?
IBKR does not facilitate the transfer of CFD positions at this time.
Are charts available for Share CFDs?
Yes.
In what type of IBKR accounts can I trade CFDs e.g., Individual, Friends and Family, Institutional, etc.?
All margin and cash accounts are eligible for CFD trading.
What are the maximum a positions I can have in a specific CFD?
There is no pre-set limit. Bear in mind however that very large positions may be subject to increased margin requirements. Please refer to CFD Margin Requirements for more detail.
Can I trade CFDs over the phone?
No. In exceptional cases we may agree to process closing orders over the phone, but never opening orders.
Overview of the OneChicago NoDiv Contract
The OneChicago NoDiv single stock futures contract (OCX.NoDivRisk) differs from the Exchange's traditional single stock futures contract by virtue of its handling of ordinary distributions (e.g., dividends, capital gains, etc.). Whereas the traditional contract is not adjusted for such ordinary distributions (the discounted expectations are reflected in the price), the NoDiv contract is intended to remove the risk of dividend expectations through a price adjustment made by the clearinghouse. The adjustment is made on the morning of the ex-date to ensure that the effect of the distribution is removed from the daily mark-to-market or cash variation pay/collect.
For example, assume a NoDiv contract which closes at $50.00 on the business day prior the ex-date at which stockholders of a $1.00 dividend are to be determined. On the ex-date OCC will adjust that prior day's final settlement price from $50.00 downward by the amount of the dividend to $49.00. The effect of this adjustment will be to ensure that the dividend has no impact upon the cash variation pay/collect as of ex-date close (i.e., short position holder does not receive the $1.00 variation collect and the long holder incur the $1.00 payment).
