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https://www.investopedia.com/terms/v/variable-prepaid-forward-contracts.asp
Mar 23, 2018 · Variable Prepaid Forward Contracts: An agreement to give a predetermined number of shares to a brokerage firm, with the stipulation of officially transferring title at some future date. The ...Author: Will Kenton
https://blogs.cfainstitute.org/investor/2012/01/18/prepaid-variable-forwards-hedging-risk-and-deferring-taxes/
Jan 18, 2012 · According to the article, Lauder used a prepaid variable forward (PVF) — also known as a variable prepaid forward — to sell $72 million of stock to an investment bank in 2014 at a price of around 75% of its present value in exchange for cash.
http://www.woodllp.com/Publications/Articles/pdf/Prepaid.pdf
Prepaid Forward Contracts: What’s All the Fuss? By Robert W. Wood • Wood LLP • San Francisco There has been significant discussion over the last five years of prepaid forward contracts and various other transactions and instruments that are similar. Some recent discussions have been prompted (or at least punctuated) by Anschutz
https://www.thetaxadviser.com/issues/2018/feb/no-gain-extension-prepaid-forward-contract.html
The rationale for affording open transaction treatment to [variable prepaid forward contracts] is the existence of uncertainty regarding the property to be delivered at settlement. . . . The [extensions] made only one change to the original [contracts]: The settlement and averaging dates were postponed.
https://www.clm.com/publication.cfm?ID=295
Jul 30, 2010 · In a much-anticipated decision, the Tax Court has held that a taxpayer who entered into a variable prepaid forward contract and a related stock loan with the same counterparty had in substance sold the underlying securities as a matter of tax common law. [1] …
https://www.investment-and-finance.net/derivatives/v/variable-prepaid-forward-contract.html
Variable Prepaid Forward Contract. A forward contract that involves the purchase or sale of a contingent number of shares which will be delivered at some future date, in exchange for immediate cash today. However, the number of shares- and likewise their exact cash value- isn’t determined until maturity, based on the underlying stock’s price at that time.
http://www.woodllp.com/Publications/Articles/pdf/Prepaid_Forward.pdf
Prepaid Forward Contracts Aren’t All Bad By Robert W. Wood There is significant discussion these days of prepaid forward contracts and various other trans-actions and instruments that are more or less simi-lar. Some renewed considerations have been prompted by Anschutz Co. v. Commissioner, recently decided by the Tenth Circuit.1 If you have readFile Size: 123KB
https://www.investment-and-finance.net/derivatives/p/prepaid-forward-contract.html
Prepaid Forward Contract. A forward contract that calls for payment today and delivery of the underlying asset or commodity at a future date. This contract entails the delivery of one unit of the underlying asset at some future date for a price determined today and payable today.
https://www2.deloitte.com/content/dam/Deloitte/us/Documents/financial-services/us-fsi-mckelvey.pdf
Tax court rules the extension of variable prepaid forward contracts is not a taxable event . On April 19, 2017, the United States Tax Court, in Estate of Andrew J. McKelvey v. Commissioner (“McKelvey”), 1 held that the extension of certain variable prepaid forward contracts (“VPFC”) did not
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