ITB 11-16: IRS ruled that a certificate issued by a life insurance company will be considered an annuity contract

Insurance Tax Bulletin

In dual private letter rulings (PLR 201105004 and PLR 201105004) the Service ruled that a certificate issued by a life insurance company through a wholly owned subsidiary to the owners of managed investment accounts will be considered an annuity contract within the meaning of Section 72 for federal income tax purposes, and would be eligible for the life insurance products exemption from the Section 475 mark-to-market rules.



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