Title

Tax Practice Corner

Department

Accountancy

Document Type

Article

Publication Date

6-2008

Abstract

The article analyzes the significance of the United States Internal Revenue Service (IRS) Coordinated Issue Paper number LMSB-04-1207-077, in which the IRS underscored its legal justification for regarding a variable prepaid forward contract (VPFC) that includes a share lending agreement (SLA) as resulting in a taxable sale. VPFCs had been regarded as a viable strategy to obtain cash from a highly appreciated stock position without triggering gain.

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