TAX CLIENT ALERT: 9th Circuit Holds Certain Securities Lending Transactions Do Not Qualify for Nonrecognition Treatment

    View Author 3 October 2011
    In Samueli v. Comm’r, the U.S. Court of Appeals for the 9th Circuit held that a purported securities loan entered into for the purpose of avoiding taxable income for the lender does not qualify for nonrecognition treatment as a securities loan pursuant to section 1058 of the Internal Revenue Code of 1986, as amended.