2008•DigitalCommons - Kennesaw State University (Kennesaw State University)Open access

Share Loans Under IRS Microscope

A. Bruce Clements

Abstract

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.

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Key concepts: Business, Counterparty, Cash, Monetary economics, Shareholder, Portfolio, Finance, Economics