Rulings on Policyholder Tax Issues
- PLR 200036021 (June 7, 2000) (Ruling held that a term certain annuity could retain its tax qualification as an “immediate annuity” under I.R.C. § 72(u)(4), even though it had certain features that might be considered as more akin to a deferred annuity);
- PLR 9941036 (July 21, 1999) (First ruling on information reporting requirements under I.R.C. § 6041 for damage payments under structured settlements to individuals who may have sold their rights to factoring companies);
- PLR 9437028 (June 17, 1994) (First ruling holding that payments under a structured settlement agreement that were indexed to the Consumer Price Index were fixed and determinable within the meaning of I.R.C. § 130(c)(2)(A));
- PLR 9305013 (Nov. 9, 1992) (supplemented by PLR 9338018 (June 24, 1993)) and PLR 9239026 (June 29, 1992) (supplemented by 9338023 (June 24, 1993)) (First rulings preserving grandfathered and other favorable tax attributes under I.R.C. §§ 7702, 7702A, 101(f), 264 and 72 of life and annuity contracts restructured in state rehabilitation proceedings, and rulings on the tax impact of proceedings on company tax issues); the firm also received many similar rulings on later transactions;
- PLR 9203009 (Jan. 29, 1991) and PLR 9117011 (May 18, 1990) (First rulings holding that the grandfathered tax status of life insurance contracts under I.R.C. §§ 7702, 7702A and 264 is not eliminated by a contract change allowing policy loan interest to be charged in arrears, rather than in advance);
- PLR 9106050 (Nov. 16, 1990) (First and only rulings of a regulatory nature under I.R.C. § 7702, the tax definition of a life insurance contract; rulings relate to the tax treatment of qualified and non-qualified additional benefits); and
- PLR 8604033 (Oct. 25, 1985) (The original and most favorable “carryover loan” ruling, concerning insurance policy exchanges in which policy loans are carried over to new policy).