This article presents an investment strategy that combines over-the-counter (OTC) derivatives securities with a partnership exchange fund. The objective of the strategy is to provide investors holding concentrated appreciated stock positions a way to diversify their holdings while minimizing the...

The article reviews those aspects of the 2003 Tax Act of particular importance to investment managers and investment vehicles such as mutual funds and hedge funds. The spread between the highest tax rate on ordinary income and that on net capital gain that existed prior to the Act was...