MOFO Tax Talk - Volume 1, Issue 2


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.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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