The above figures look broadly accurate but are an outside case as 50% gains in 2 months are outside the norm.I'm interested in the tax side of the transaction but I'm trying to get my head straight on your proposal and strategy.
A big assumption is that the option side of the trade carries income tax treatment, but as you are assuming that, let's run with it for the sake of an example.
Let's assume a simple example - there are just 2 accounts: ARF A/C & OPTION A/C - and all we are seeking to do is understand the interaction of the accounts based on price movements and the tax implications following on from the price movements. Other trade iterations can be brought in later, but the strategy needs to stand up in its simplest form first.
Assumptions:
At time 'T':
Option position and type: Short an out-of-the-money (OTM) Call Option
S (share price): 100
X (exercise price): 110
P (option price): 1
Tax Rate of the individual: 25% (income tax plus USC)
Account Status at time T:
ARF A/C: Long one share valued @ 100
OPTION A/C: Short an OTM call option on the share with an exercise price of 110 and maturity T+1. Option seller receives the premium of 1.
At time 'T+1':
S: 150 (increase in price of the share of 50%)
X: 110
P: 40 (S-X)
Account Status at time T+1:
ARF A/C: Share is worth 150. Gross gain of 50.
OPTION A/C: Short option position is closed out by going long a call with same strike and maturity. Realised trading loss of 39 (premium received of 1 less 40 cost of offsetting option position).
Monies have to come across from ARF A/C to fund the cash shortfall in OPTION A/C. The share is sold in the ARF A/C. ARF A/C is long cash of 150.
To fund the OPTION A/C, 52 (39/(1-0.25)) needs to be taken from the ARF A/C. 39 is transferred to the OPTION A/C and 13 is paid in tax.
Is your net worth now in negative territory? +50 on the share, -39 option trading, -13 in tax, resulting in a net position of -2 (and worse if subject to a higher tax rate)?
Perhaps the strategy is to use the 39 loss ("trading loss") against your PAYE (income tax and USC) of 13 to put your net worth back in positive territory?
If you are using a trading loss against other income (a Section 381 loss), the full loss has to be used. 13 of the 39 loss can't be used against the PAYE tax of 13 with the balance carried forward to use in future years against the same trade (the trade of option trading). You would need to have scope to use the full 39 in the same year. The trading loss also can only offset income tax and not USC. In addition, if the trade is carried out in a non-active capacity, loss relief is not prevented, but it is limited (Section 381B), further crimping the potential utilisation (in a particular tax year).
Does the above broadly match what you have in mind? Have you gotten tax advice on the strategy?
This scenario of a small loss, but only if you were unable to offset the trading losses against other gains, may have been encountered had you followed the strategy at the wrong time with the likes of NVDA. However, also remember that if you aim for a 1% premium with a stock so volatile that 50% moves are possible, you end up going WAY out of the money. For example, shooting for a 1% premium with 2 months until expiry with NVDA today has you going 62.5% out of the money as opposed to the 12-15% you'd see with a typical stock.
The strategy definitely doesn't work well if all your positions were to rise 50%+ during the 2 month holding period and you were unable to offset the losses against other gains.
I do find that the bulk of options with premiums representing 1% of strike, and with 2 months remaining until expiry, will expire out of the money. On average, you would see the occasional one expire a little in-the-money but it'd be very rare to have anything expire as deep in-the-money as the above sample.
Continued use of the strategy would be monitored as the year progresses and it's much easier to continue if there are already profits that potential future losses can be offset against.
In short, the above is a risk but I don't believe the risk of a small loss encountered in such an extremely rare scenario would deter me from the strategy - even ignoring the potential of future gains making this particular trade net-positive again.
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