Description: The article summarizes PLRs 201515001 and 201519001, in which the IRS addressed the treatment of a non-qualified deferred annuity contract under the investor control doctrine and other applicable rules. The contract provides a guaranteed lifetime withdrawal benefit and investment options that correspond to “public” mutual funds. The IRS concluded that the investor control doctrine will apply to treat the contract purchaser as the owner of the mutual fund shares for federal income tax purposes. The IRS also addressed certain other tax aspects of the arrangement. The effect of the rulings is that the contract will be taxed similarly to a contingent deferred annuity (where the policyholder holds the mutual fund shares in his or her own brokerage account), while being structured like a traditional deferred variable annuity (where the insurance company holds the shares in its separate account).

Description: This paper responds to comments on a proposed compulsory savings program combined with transparent investment vehicles designed to promote competition based on expense levels, fund performance and customer service. At retirement 50% of the account is annuitized in Participating Variable Annuity (PVA) backed by TIPS. All investment experience, expenses, and pooled longevity experience is passed to annuitants through periodic benefit adjustments. Annuities are priced uniformly based on age at commencement.