Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: Report presenting the 1976-86 mortality experience for contracts issued in the U.S. through 1985 under individual immediate annuities, life income settlements, and matured deferred annuities.

Description: Study of mortality experience under Canadian individual annuities for 1980 - 1988 anniversaries. Most policies studied are in the payout status, though experience is additionally included during the deferred period provided the policy has no cash value or right to change the policy.

Description: Covers mortality experience under Canadian individual payout annuities and certain deferred annuities which have no cash value or no right to change the policy.