With the ongoing financial crisis, there are more and more bankruptcies and credit downgrades. These events can result in terminations of existing derivative contracts and stock lending agreements. With such early terminations, the expected tax treatment is often thrown out the window. Transactions that were entered into based on expectations of particular tax results are faced with adverse tax consequences. In this program, Andrea Kramer, a partner in McDermott Will & Emery LLP, addresses the tax implications of (1) bankruptcies (and credit downgrades) on open derivative contracts and (2) bankruptcies of stock lenders with open stock lending agreements.