Tax Talk, June 2008

MoFo TaxTalk, Volume 1, Issue 2 discusses U.S. federal income tax issues that affect the capital markets and financial products arena. Specifically, this issue of TaxTalk covers:

*An update on recent mega hybrid deals;

*Credit Crunch results in Remic Relief and the IRS provides for liquidity with respect to Auction Rate Securities;

*Section 1260 (Constructive Ownership Transactions);

*The IRS' view on Variable Prepaid Forward Contracts plus Share Loans;

*Specific issues regarding Revenue Ruling 2003-9; Sovereign Wealth Funds; the Samurai Market.