Tax Practice Corner
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.
Clements, A. B. (2008). Tax practice corner. Journal of Accountancy, 205(6), 90-90.