IRCCourt RulingsDec 24, 1985★ strong match
…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…
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 200711014 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsMar 16, 2007★ strong match
…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…
89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern IRCFinal Rules (FR)May 6, 2024related by meaning
tment of section 30D(g) (that is, August 16, 2022) pursuant to section 104 of the Federally Recognized Indian Tribe List Act of 1994 (25 U.S.C. 5131). Section 30D(g)(10) provides that in the case of any taxpayer who has made a credit transfer election with respect to a new clean vehicle and received a payment from an e…
IRCCourt RulingsAug 31, 1964★ strong match
…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…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
ble and Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A). (56) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for…
IRCPrivate Letter RulingsJun 17, 2016★ strong match
for another annuity contract. The legislative history of § 1035
explains that § 1035 provides non-recognition treatment for taxpayers who have “merely exchanged an [annuity contract] for another better suited to their needs and who have
not actually realized gain.” H. Rep. 1337, 83d Cong., 2d Sess. 81 (1954). Un der
§ …
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
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…
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 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…
See
Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021).
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/05/03/provider-charges-relative-to-medicare-rates-2012-2018/.
Back to Citation
210…
IRCCourt RulingsFeb 9, 2023related by meaning
efinition of an applicable foreign
legal restriction and the taxpayer has elected the deferred
income method of accounting, any section 482 allocation connected with the transaction will be defer rable until the
restriction is removed. Deductions and credits chargeable
against a deferred amount are subject to deferral …
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
IRCFinal Rules (FR)Nov 8, 2011related by meaning
sthroughs and Special Industries), IRS.
List of Subjects in 26 CFR Part 20
Estate taxes
Reporting and recordkeeping requirements
( printed page 69128) Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 20 is amended as follows:
PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954
Paragra…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
nd Similar Gifts.—Whether a transfer to a pooled income fund described in § 642(c)(5) qualifies for a charitable deduction under § 2522(c)(2)(A).
(48) Section 2522.—Charitable and Similar Gifts.—Whether a transfer to a charitable remainder trust described in § 664 that provides for annuity or unitrust payments for one …
Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex… IRCNoticesNov 13, 2007related by meaning
g whether an estate making the section 6166 election will be required to provide security.
TAX CONVENTIONS
Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…