CVRs -- CVR's are, I understand, fairly rare in tender offers, obviously Sanofi-Aventis Genzyme is a well known example of a CVR in a tender offer. I'm assuming that the CVR's themselves trade or otherwise have an ascertainable value, in that case, in a taxable tender, the recipient will likely be required to include the CVR in income when received. If the CVR does not trade and does not have an ascertainable value, there is an argument that you can defer recognition. The Sanofi-Aventis disclosure took the position that the receipt of the CVR was taxable, but that the subsequent tax consequences are unclear. http://yahoo.brand.edgar-online.com/EFX_dll/EDGARpro.dll?FetchFilingHTML1?ID=7827380&SessionID=vGoT6Fr1Ic73B_7#D424B3_HTM_ROM153596_36A
This article by Wachtell Lipton discusses CVR's, with some discussion of tax.
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