IRS Issues PLR Treating Indexed Structured Settlement Annuities as Qualified Funding Assets

May 26, 2026, 1:26 PM UTC

The IRS has issued a private letter ruling on I.R.C. §130 clarifying that indexed structured settlement annuity payments tied to market index performance qualify as fixed and determinable periodic payments, confirming that annuity contracts with fluctuating payments based on objective formulas meet qualified funding asset requirements for personal injury liability assignments. [PLR 202621001]

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