Government Industry
Industry: Email Alert RSS FeedNotice 2008-2
United States. Internal Revenue Bulletin, January, 2008 by Anonymous
Timing, Character, Source and Other Issues Respecting Prepaid Forward Contracts and Similar Arrangements
SECTION 1. PURPOSE
The purpose of this notice is to request comments from the public with respect to issues that arise in connection with certain financial transactions frequently referred to in the marketplace as prepaid forward contracts (or in certain circumstances as exchange traded notes).
SECTION 2. BACKGROUND
The Internal Revenue Service and the Treasury Department are considering the tax policy issues raised by certain financial transactions frequently referred to in the marketplace as prepaid forward contracts (or in certain circumstances as exchange traded notes). These transactions resemble typical forward contracts (that is, bilateral,...
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