IRS PLR: Contingent Deferred Annuity Contract Qualifies as Annuity (IRC §72)

The IRS ruled that a contingent deferred annuity contract qualifies as an annuity contract under § 72. The ruling covers the tax treatment of the contract’s guaranteed payments, the lack of cash surrender value, the investment in the contract calculation, the treatment of dividends from linked investment accounts, the absence of a straddle, and the non-applicability of the tax benefit rule. [PLR 202503002]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.