ITB 11-33: IRS rules that investment contracts will be treated as annuities

Insurance Tax Bulletin

In PLR 201128017, the IRS ruled that contracts that require an insurance company to pay a benefit to an owner of an investment account if the value of the account falls below a specified amount, will be treated as an annuity contract under section 72 and will qualify exemption from section 475 mark-to-market rules.

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