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Share Loans Under Irs Microscope, A. Bruce Clements
Share Loans Under Irs Microscope, A. Bruce Clements
Faculty and Research Publications
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.