The chips use a technology called "code morphing, " which Transmeta says lets them run the same x86-type instructions as Intel processors, but with less power.
If the IRS follows the same rule for event-type CVRs, the issuer recognizes no gain or loss on the CVR issuance, the repurchase of the CVR, or the lapse of the CVR, but a target shareholder generally must recognize an immediate capital gain or loss taking into consideration the fair market value of the CVRs received on the date of distribution.