In PLR 201128017,IRS has privately ruled that contracts offered by a life insurance company to certain investment account owners that obligate the company to pay a benefit if a customer’s account falls below a specified value, are annuity contracts under Code Sec. 72. Accordingly, any such benefits paid to the customers will be considered “amounts received as an annuity,” and the fees paid by the customers for the contracts will be factored into their investment in the contracts for Code Sec. 72(b) purposes.

The Beliveau Law Group: Massachusetts | Florida | New Hampshire

The attorneys at The Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation (federal and state), and civil litigation (in connection with these practice areas). The law firm has offices and attorneys in Naples, Florida; Boca Raton, Florida; Danvers, Massachusetts; Waltham, Massachusetts; Quincy, Massachusetts; Manchester, New Hampshire and Salem, New Hampshire.