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Variable Prepaid Forward Contracts (VPFCs)

Cadwalader, Wickersham & Taft LLP

Beware of Monsters

In a rare application of Section 1234A, the Tax Court has held that extending the settlement dates of a set of variable prepaid forward contracts (“VPFCs”) was an exchange for a second set of VPFCs that terminated the...more

Proskauer - Tax Talks

Tax Court Rules that Extensions of Variable Prepaid Forward Contracts Do Not Result in Taxable Exchanges

Proskauer - Tax Talks on

Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical variable prepaid forward contract (“VPFC”) did not give rise to a taxable exchange to the obligor because a VPFC is solely an...more

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