IRS PLR: Certain Advisory Fees Deducted From Annuity Contract Cash Value Not Amounts Received by Owners (IRC §72)

The IRS has published a private letter ruling on Section 72 determining that certain investment advisory fees a stock life insurance company deducts from the cash value of non-qualified deferred annuity contracts, and remits to a registered investment adviser, will not be treated as an “amount received” by the owner of the contract for purposes of Section 72(e). [PLR 202431004]

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