The memorandum discusses the treatment of a transaction involving 100,000 shares of Bear Stearns stock, which were converted into JP Morgan Chase shares. JEE owes FTC 21,753 shares of JPM stock and dividends on the borrowed stock. The document outlines steps to 'clean up' the stock loan, including purchasing JPM shares and arranging delivery to FTC. It also discusses the tax implications of treating the transfer as a loan or a gift.
documents/EFTA00726911.pdf
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