An article written by Buchanan Ingersoll attorney Deborah M. Beers was reprinted in the December 2005 edition of the Capco Institute's Journal of Financial Transformation. The article originally appeared in the February 9, 2004, issue of Tax Management.
The article, titled "New Guidance on Structuring Hedge Fund Investments Within Variable Life and Annuity Contracts," discussed two revenue rulings issued in 2003 by the Treasury and the Internal Revenue Service that were aimed at restricting the practice of using life insurance and annuity contracts to avoid taxation on investment earnings.
Beers reveals in the article that, although the rulings seemed to initially deal a blow to insurance-wrapped hedge funds, the new regulations actually offer guidance on how to successfully structure hedge fund investments within variable life and annuity products within the confines of the rulings.
The Journal of Financial Transformation is dedicated to the advancement of leading thinking in the field of applied finance. The journal provides a unique link between scholarly research and business experience, and aims to be the main source of thought leadership in the discipline for senior executives, management consultants, academics, researchers and students.