Short Selling

The essence of trading is buying and selling financial products for income. If you think the asset will rise in value, buy first and sell afterward — this is known as a “long position.” If you want to speculate on declining value, borrow the security to sell it first and then buy it later to close the short position — this is “selling short.” (There are other ways to speculate on market drops, like buying put options or inverse ETFs, both of which are long positions.)

There are two types of short sales: (1) a short sale and (2) a short sale against the box. Both involve borrowing securities from another account holder arranged by a broker.


Short selling is not free; a trader needs a broker to arrange a stock loan. Brokers charge short sellers “stock borrow fees” or “loan premiums.” Tax research indicates these payments are “fees for the temporary use of property.” Watch out: Many brokers refer to stock borrow fees as “interest expense,” which confuses short sellers and their accountants.

Stock borrow fees are business expenses when the taxpayer has TTS. 

There are many unique tax rules for short sellers, including constructive sales on appreciated positions, dividends and payments in lieu of dividends, dividend issues for the short seller, dividend issues for the lender, and traders versus investors.

Excerpt from Green’s Trader Tax Guide Chapter 16 Short Selling.