SIH Partners: Tax Court Applies Anti-Abuse Rule to 70/30 Basket Hedge Structure

A recent decision demonstrates that satisfying the mechanical 70/30 overlap test alone is insufficient to protect a basket hedge where the transaction’s economics indicate that its principal purpose was tax savings. On August 6, 2026, the U.S. Tax Court issued its opinion in SIH Partners LLLP v. Commissioner, 167 T.C. No. 8. At issue was […]