1545-BH47 202304 Unified Agenda of Federal Regulatory and Deregulatory Actions 1545 Internal Revenue Service IRS 1500 Department of the Treasury TREAS Exchange of Property for an Annuity

This regulation proposes application of the installment sale rules to the exchange of property for a private annuity contract. This project would address the inappropriate avoidance or deferral of gain on the exchange of highly appreciated property for the issuance of an annuity contract, for example, when a taxpayer transfers highly appreciated property to a related party in return for an annuity and the related party sells the property to an unrelated party and does not pay tax on the sale.

]]> Substantive, Nonsignificant Previously Published in The Unified Agenda Proposed Rule Stage No No Not Yet Determined 26 U.S.C. 7805 26 U.S.C. 453 No NPRM 12/00/2023 REG-140454-07 (NPRM) Drafter attorney: Edward C. Schwartz (202) 317-4740 Reviewer attorney: Amy J. Pfalzgraf (202) 317-4716 Treasury attorney: N/A CC:ITA No None No No No Edward Schwartz C. General Attorney (Tax) 1545 Internal Revenue Service IRS 202 317-4740 855 576-2339 edward.c.schwartz@irscounsel.treas.gov 1111 Constitution Avenue NW., Room 4236, Washington DC 20224