Acquisitions, Dispositions & Structuring Techniques Corner: Tax Court’s Recent Decision In Mckelvey Est., Affirms Merits Of Deferring Gain Under A Variable Prepaid Forward Contract

By Jerald David August
Journal of Passthrough Entities
September – October 2017 Edition

In McKelvey, the executor of the taxpayer’s estate petitioned for a redetermination of the $41.26M deficiency in income tax for 2008, processed by the IRS, attributable to his entering into various variable prepaid forward contracts (“VPFCs”) with respect to shares of stock in Monster.com. Andrew McKelvey was the founder of the Company.

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