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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)




Journal of Taxation and Regulation of Financial Institutions

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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.

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