Prepaid Forwards, Structured Products and ETNs: How IRS Notice 2008-2 Might Affect the Industry

12/19/2007

Capital Markets, Federal Tax, Derivatives + Commodities, and Structured Products

New York, NY

Thomas A. Humphreys

Thomas A. Humphreys

Seminar

Morrison & Foerster hosted this timely and important event concerning the Treasury’s December 7 Notice 2008-2, which asked the public for comments on “prepaid forward contracts (including ETNs).” The event provided attendees with insight on how the Treasury came to look at the taxation of prepaid forwards (including ETNs); the opposition to the growth of structured products; and what an adverse ruling on the part of Treasury could portend for the industry.

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