IN THIS ISSUE:

2 The Dodd-Frank Act – Trust Preferreds, Covered Bonds, and Section 1256 Contracts

3 Proposed Regulations Clarify Ambiguity in Debt Modification Regulations

3 Summitt v. Comm’r – Foreign Currency Options Are Not Section 1256 Contracts

4 Calloway v. Comm’r – Purported Stock Loan Treated as Sale

5 Tax Patents – Update on In Re Bilski

6 From Extender’s Act to American Jobs and Closing Tax Loopholes

Act to Nowhere

6 The Classroom – RICs and Commodity Linked Structured Notes

7 Press Corner

7 MoFo in the News