From: jeffrey E. <[email protected]> Sent: Saturday, September 26, 2015 10:46 AM To: Halperin, Alan S Subject: Re: why is not semi annual payments with the last paymen= on the anniversary date qualify, it was only the choice of an=versary or tax year? On Sat, Sep 26, 2015 at 6:41 AM, Halperin, Alan S <a wrote: An annuity paid on the anniversary date is an annual annuity (and probably =he last annuity payment on other types of payment schedules). Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP 1285 Avenue of the Americas New York,=C2 NY 10019-6064 <http://www.paulweiss.com> From: jeffrey E. Sent: Saturday, September 26, 2015 1:09 AM To: Halperin, Alan S Subject: https://www.law.cornell.edu/cfr/text/26/25.2702-3 <https://www.law.cornelLedu/cfr/text/26/25.2702=3> =C2 i only see the limitation of the 105 day look back to be=based on anniversary date. i dont see the annual min req that =ou mentioned. please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_01605495 EFTA02486490