Private Letter Rulings

• PLR 1999-41036 [.pdf]
  • Factoring -- Tax Information Reporting
    
    
• PLR 1999-42001 [.pdf]
  • Variable Annuity; Secured Creditor
    
    
• PLR 1999-43002 [.pdf]
  • Variable Annuity; Secured Creditor
    
    
• PLR 2001-40031 [.pdf]
  • Granting Taxpayer an extension of time to make the relation-back election under § 1.46833-1(j)(2)(i) will not prejudice the interests of the government.
    
    
• LR 2001-49013 [.pdf]
  • The Trust established under these facts constitutes a qualified settlement fund under § 1.468B-1(c) of the Internal Revenue Code; The Trust will be subject to tax on its modified gross income; The transfer of cash and company stock into the fund to resolve the liability that the Trust was created to assume, will not constitute gross income to the Trust; and
    Company will generally be entitled to deduct transfers made to the Trust in the year of each payment.
    
    
• PLR 2002-13015 [.pdf]
  • The Escrow Account would be a qualified settlement fund (QSF) under § 468B(g) of the Internal Revenue Code and any income earned by the Escrow Account would be includible in the Escrow Account’s income.
    
    
• PLR 2002-16013 [.pdf]
  • Funds located in an escrow account set up by Corporation to fund settlement payments satisfied the requirements of § 1.468B-1(c) and therefore did qualify under a qualified settlement fund under § 468B.
    
    
• PLR 8333035 [.pdf]
  • Knowledge of cost does not constitute constructive receipt

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Revenue Rulings

• 79-220 1979-2 C.B. 74 Section 104 [.pdf]
  • Damages; monthly payments; amount excludable. An insurance company purchased and retained exclusive ownership in a single premium annuity contract to fund monthly payments stipulated in settlement of a damage suit. The recipient may exclude the full amount of the payments from gross income under section 104(a)(2) of the Code rather than the discounted present value. Payments made to the estate after the recipient's death are also fully excludable.
    
    
• IRS Revenue Ruling 2003-115, 10-28-03
  • Expressly permits structured settlements to be done from the September 11 Victims' Compensation Fund by means of section 130 qualified assignments.

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