From: Halperin, Alan S < Sent: Saturday, September 26, 2015 10:52 AM To: Jeffrey E. Subject: Re: The annuity payment must be paid within the specified window (that is withi= 105 days of the anniversary date or calendar year). There is no express a=thority of how to apply this rule (providing administrative convenience) w=en the annuity is payable multiple times a year. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP 1285 Avenue of the Americas I New York,&=bsp;NY 10019-6064 www.paulweiss.com From: Jeffrey E. Sent: Saturday, September 26, 2015 6:45 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 = < <mailto 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 I New York,&=bsp;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.cornell.edu/cfr/text/26/25.2702=3> =nbsp; 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 you mentioned. please note EFTA_R1_01605536 EFTA02486521