IRS Reiterates Stand on Variable Prepaid Forward Contracts
Author: Howard J. Barnet, Jr..
Source: Volume 20, Number 05, May/June 2007 , pp.40-42(3)
< previous article |next article > |return to table of contents
Abstract:
The Service’s contention is that, although a VPFC without a securities loan agreement would be nontaxable under Rev. Rul. 2003-7, and a securities loan without a VPFC would pass muster under Section 1058, the combination of the two is a taxable sale.Keywords:
Affiliations:
1: Carter Ledyard & Milburn LLP.