IRS PLR: Contingent Deferred Annuity Contract Rulings in Context of Investment Account Also Owned by Taxpayer (IRC §72)

For purposes of I.R.C. §72 income inclusion, the IRS ruled: A contingent deferred annuity contract that a U.S. citizen (“Taxpayer”) plans to purchase from a life insurance company will constitute an annuity contract, and a taxable investment or brokerage account — the depletion of which before Taxpayer’s death would trigger Contract to provide retirement benefits — will not be part of Contract or cause it to have a “cash value” or “cash surrender value.” Such Contract payments will be taxable as “amounts received as an annuity” with certain exclusions (specified), and the “aggregate amount of premiums or other consideration ...