IRCCourt RulingsDec 30, 1998
…ts be the same person. No other requirements are set forth in the applicable regulations. Section 1.1035-1(c), Income
Tax Regs., provides, in part, as follows:
Sec. 1.1035-1. Certain exchanges of insurance
policies.--Under the provisions of section 1035 no gain or
loss is recognized on the exchange of:
* * * * * * *
(c…
PLR 202625002 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJun 18, 2026
…ity” that is taxable under the “exclusion ratio”
methodology of § 72(b).
Requested Ruling 8 Section 1035(a) provides that no gain or loss shall be recognized on the exchange of an
annuity contract for an annuity contract.
Section 1035(d)(1) provides that if an exchange is not solely in kind, the rules of
§§ 1031(b) and…
PLR 202625003 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJun 18, 2026
…ity” that is taxable under the “exclusion ratio”
methodology of § 72(b).
Requested Ruling 8 Section 1035(a) provides that no gain or loss shall be recognized on the exchange of an
annuity contract for an annuity contract.
Section 1035(d)(1) provides that if an exchange is not solely in kind, the rules of
§§ 1031(b) and…
PLR 200622020 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJun 2, 2006
y under sections 72 and 1035 of the Internal Revenue Code.
FACTS
Taxpayer is an individual. On Date 2, a non-qualified Annuity (Annuity) was purchased and held by Trust, a revocable trust with Taxpayer and Spouse as Grantors and
Trustees. Spouse died on Date 3. Upon the death of Spouse, Taxpayer asked the
insurance com…
IRCRegulationsJul 9, 2026
…ife insurance policies have been gratuitously transferred or issued in an exchange to which section 1035(a) or section 1031 (to the extent it relates to section 1035(a)) applies (section 1035 exchange) is stated in paragraph (b)(2) of this section.
IRCCourt RulingsDec 16, 2015
…was actually transferred to the BS Plan and (2) that transfer was exempt from tax under I.R.C. sec. 1035, which provides for
nonrecognition of gain on an exchange of life insurance policies. R
argues that (1) Ps were taxable in 2003 under I.R.C. sec. 402(b)(1) or
(2), either when H terminated its participation in the A…
IRCCourt RulingsDec 24, 1985
…nnuitant only in installments.
Respondent’s regulations, in turn, provide in pertinent part:
Sec. 1.1035-1. Certain exchanges of insurance policies. Under the provisions of section 1035 no gain or loss is recognized on the exchange of—
(c) An annuity contract for another annuity contract (section 1035(a)(3)), but secti…
PLR 200711014 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsMar 16, 2007
…he exchange of the Old Contracts for New Contracts will
qualify as tax-free exchanges under section 1035(a). Section 1035(a) of the Internal Revenue Code provides that no gain or loss is recognized on the exchange of -- (1) a
contract of life insurance for another contra ct of life insurance or for an endowment or
annu…
IRCPrivate Letter RulingsJul 26, 2013
…ew owner of th e annuity contract and controls the use of the cash value of the contract.”)
Section 1035(a)(3) provides that no gain or loss shall be recognized on the exchange of
an annuity contract for an annuity contract. Section 1035(b)(2) defines an annuity
contra ct for purposes of § 1035 to be a contract of endo…
86 FR 708 — Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Interm… IRCFinal Rules (FR)Jan 6, 2021
2 (FDIC) (“synthetic exposure”).
Back to Citation
32.
See 12 CFR 3.2 (OCC); 12 CFR 217.2 (Board); 12 CFR 324.2 (FDIC) (“investment in the capital of an unconsolidated financial institution” and “indirect exposure”).
Back to Citation
33.
See 12 CFR 44.4 (OCC); 12 CFR 248.4 (Board); 12 CFR 351.4 (FDIC).
Back to Citat…
IRCCourt RulingsAug 31, 1964
…an the date payments would have begun under the contract exchanged, or an annuity contract (section 1035 (a) (2)); or (c) An annuity contract for another annuity contract (section 1035(a)(3)), but section 1035 does not apply to such exchanges if the policies exchanged do not relate to the same insured. The exchange, wi…
88 FR 75744 — Federal Independent Dispute Resolution Operations IRCProposed Rules (FR)Proposed Nov 3, 2023
ation
133.
Proposed 26 CFR 54.9816-8(b)(2)(ii)(A)(
5), 29 CFR 2590.716-8(b)(2)(ii)(A)(
5), and 45 CFR 149.510(b)(2)(ii)(A)(
5).
Back to Citation
134. Currently, the administrative fee is paid to the selected certified IDR entity and then remitted to the Departments. 26 CFR 54.9816-8T(d)(2)(i) and (e)(2)(ix), 29 CFR 2…
IRCPrivate Letter RulingsJun 17, 2016
…ribution of those distributed funds to Annuity 2 will be treated as a tax deferred exchange under § 1035(a)(3) of the Code and will not result in the imposition of income
tax und er § 72(e) of the Code; and
2. That no further corrective transactions are required as between Annuity 1
and Annuity 2 in that, although the …
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsApr 8, 2024related by meaning
(b) (b) Describe the scope of relief and any conditions of the proposed exemption;
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
[Reserved]