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TREAS/IRS | RIN: 1545-BH47 | Publication ID: Spring 2020 |
Title: Exchange of Property for an Annuity | |
Abstract:
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. A taxpayer transfers highly appreciated property to a related party in return for an annuity. The related party sells the property to an unrelated party and does not pay tax on the sale. |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
EO 13771 Designation: Other | |
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 453 |
Legal Deadline:
None |
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Timetable:
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Additional Information: 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 | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Edward C. Schwartz General Attorney (Tax) Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 4236, Washington, DC 20224 Phone:202 317-4740 Fax:855 576-2339 Email: edward.c.schwartz@irscounsel.treas.gov |