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: Provides in-depth discussion of IRS Rev. Proc. 2008-24, including tax background of partial annuity exchanges. Then discusses partial annuitizations and “modified endowment contracts.”

Description: The article discusses PLR 201632004, which addresses the partial annuitization rules of IRC section 72(a)(2) in the context of a deferred income annuity rider attached to a variable deferred annuity contract.

Description: This is an article about how to place value on an annuity benefit.

Description: The article discusses an IRS private letter ruling applying the after-death distribution requirements applicable to non-qualified annuity contracts under section 72(s) of the Internal Revenue Code.

Description: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.

Description: The article summarizes several recent private letter rulings from the IRS addressing the "investor control" doctrine in the context of funds of funds.