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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