Nowotny on Private Placement Group Variable Deferred Annuity Contracts for Tax Exempt and Foreign Investors
The Private Placement Group Variable Deferred Annuity Contract aka GAC has quietely been used by tax-exempt organizations for some time. As far as I can count, $50 billion of tax exempt transactions have utilized the GAC as a...more
On April 10, the Internal Revenue Service (IRS) released PLR 201515001 (Oct. 10, 2014), favorably addressing a “taxable annuity”—essentially, a deferred annuity contract supported, in part, by subaccounts, each of which...more
Guidance addresses nondiscrimination, qualified default investment alternative, and annuity safe harbor rules.
On October 24, the Internal Revenue Service (IRS) and the U.S. Department of Labor (DOL) each issued...more
The Life Actuarial Task Force's Index-Linked Variable Annuities (A) Subgroup (the "ILVA Subgroup") began a fresh look at the regulatory framework for annuity products. On February 6, it held a call to review its January 15,...more
American taxpayers have approximately $4.7 trillion invested in IRAs as of 2011. Only 2 percent of these assets or $94 billion are invested in self-directed IRAs. This is a surprising result when you...more
Large institutional investors including pension plans and endowments and foundations have made significant investments in timberland over the last forty years. These same investors have also made significant...more
Originally published in Tax Management Estates, Gifts, and Trusts Journal, x, 11/08/2012.
The current tax environment suffers from a lot of economic and political uncertainty. The general consensus...more
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