An Overview of the SEC’s Recently Adopted Exchange-Traded Funds (ETF) Rule
In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more
On July 12, 2024, Treasury and the IRS published proposed regulations (the “Proposed Regulations”) that would identify certain basket contract transactions as well as transactions substantially similar thereto as “listed...more
On July 17, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) identifying certain “basket contract” transactions, and transactions that are...more
The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more