Linda Carlisle's comments on straddles were quoted in Tax Analysts. Carlisle participated in a panel discussing Internal Revenue Service (IRS) straddle rules along with Mark Perwien, senior adviser (financial services), IRS Large Business and International Division and Robert Williams, branch 3 senior counsel, IRS Office of Associate of Chief Counsel (Financial Institutions and Products). A challenge for taxpayers attempting to identify straddles is that "substantial diminution of the taxpayer's risk for loss" has not been defined by the IRS, Carlisle said. The panel was part of the Practising Law Institute's Financial Products and Transactions conference in New York on January 19, 2016.
This article also appeared in Tax Notes on February 1, 2016.