News & Analysis as of

Internal Revenue Service Internal Revenue Code (IRC) Basket Transactions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Pillsbury Winthrop Shaw Pittman LLP

Vindication: The U.S. Tax Court Sustains IRS Position on Basket Options in GWA, LLC

In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more

Cadwalader, Wickersham & Taft LLP

Basket Contract Listed Transactions

On July 12, 2024, Treasury and the IRS published proposed regulations (the “Proposed Regulations”) that would identify certain basket contract transactions as well as transactions substantially similar thereto as “listed...more

Eversheds Sutherland (US) LLP

Proposed regulations add certain basket contracts to list of listed transactions

On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more

Gray Reed

IRS Further Combats Basket Contract Transactions with Proposed Regs

Gray Reed on

The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more

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