The Tenth Circuit Court of Appeals has affirmed a Tax Court decision that held that the disposition of appreciated stock via Variable Prepaid Forward Contracts (VPFC) were taxable. The underlying issue had been whether the VPFC created a taxable constructive sale. The case is Anschutz v. Comm'r, (10th Cir. 2011).
See Steven Schneider, "10th Circuit Affirms Taxability of Variable Prepaid Forward Contracts," taxlawroundup.com (Dec. 28, 2011).
Posted by Andrew Hodes, Associate Editor, Wealth Strategies Journal.
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