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- Title
Acquisitions, Dispositions & Structuring Techniques Corner.
- Authors
Lipton, Richard M.
- Abstract
In this article, the author discusses recent U.S. Tenth Circuit decision made in Anschutz Corp. involving tax treatment of a variable prepaid forward contract (VPFCs). It examines the legal test applied by the Tenth Circuit for purposes of determining that a sale occurred is very broad and could affect many common transactions, including particularly participating nonrecourse loans or mezzanine financing. It reveals that reliance on a multi-factor test on a sale could have broader application.
- Subjects
UNITED States; ANSCHUTZ Corp.; VARIABLE prepaid forward contracts; UNITED States. Court of Appeals (10th Circuit); NONRECOURSE debt; ACTIONS &; defenses (Law)
- Publication
Journal of Passthrough Entities, 2012, Vol 15, Issue 1, p7
- ISSN
1099-7407
- Publication type
Article