In This Issue:

IRS Issues Tech Advice Addressing Restructured Call Options; Second Circuit Rejects GE Capital Deal, Again; IRS Releases Field Attorney Advice Disallowing Benefits of a Dividends-Received Deduction Transaction; Treasury Publishes Highly Anticipated “Withholdable Payment” FATCA Regulations and Outlines International Cooperation Alternative; IRS Issues Guidance on Registered Bonds Days Before Repeal of Bearer Bond Exception; and MoFo in the News.

Excerpt from IRS Issues Tech Advice Addressing Restructured Call Options

In late October 2011, the IRS released a technical advice memorandum addressing whether written call options continued to be options for federal income tax purposes after being restructured, whether such restructuring of the options resulted in a Section 2 1001 event, whether the restructured options were hedging transactions, and lastly whether the taxpayer was permitted to realize the options’ losses upon closing.