- Treasury Tax Legislative Counsel Michael Desmond testified before a Subcommittee of the House Ways and Means Committee.
- Noted current regulatory ambiguity as to whether prepaid forward contracts should be taxed as debt, equity or a hybrid.
- As more such instruments migrate into retail investors’ portfolios, the Treasury Department has increased its scrutiny of tax ramifications.
- Desmond illustrated inconsistencies in alternative tax treatment based on structure of prepaid forward contracts.
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