IRS Issues PLR Confirming Variable Structured Settlement Annuities Are Qualified Funding Assets

The IRS has issued a private letter ruling on I.R.C. §§104 and 130 confirming that indexed structured settlement annuity contracts with variable payment amounts based on market index performance qualify as qualified funding assets where periodic payments include guaranteed minimum floors and objective formulas for calculating fluctuating amounts, and that such variable payments remain fixed and determinable as to amount and time of payment for qualified assignment purposes. [PLR 202618005]

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