Page 36 - Large Business IRS Training Guides
P. 36

BEP – QDP
                                                                  Exception (cont’d) 3






          The following are not derivatives  –



                               direct interest in any of the items listed on the
                  •	  Any
                      previous page


                               insurance, annuity, or endowment contract issued
                  •	  Any
                      by
                            an insurance company to which subchapter L
                      applies
                                     (or, issued by a foreign corporation, to which

                      subchapter
                                             L would apply if that corporation were a
                      domestic corporation)


                               securities lending transaction, sale-repurchase
                  •	  Any
                                                   substantially similar transaction
                      transaction, or

                  •	  American depository receipts
                                                                                  or any similar

                      instruments
                                              with respect to shares of stock in a foreign
                      corporation




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