School of Accountancy
In a recently released Coordinated Issue Paper (LMSB-04-1207-077), the IRS underscored how its examinations will home in on a once-favored strategy for monetizing stock gains while deferring capital gains taxes. In doing so, the Service reiterated its legal basis for why a variable prepaid forward contract (VPFC) that includes a share lending agreement (SLA) results in a currently taxable sale.
Journal of Accountancy
Clements, A. Bruce. "Share Loans Under IRS Microscope." Journal of Accountancy 205.6 (2008): 90.