October 24, 2014
October 23, 2014
October 22, 2014
New IRS Revenue Rulings: Amount and Character of Income on Life Insurance Contracts
On May 1, 2009, the IRS issued a pair of Revenue Rulings that significantly clarify the state of U.S. federal tax law applicable to transactions involving life insurance policies, including life settlements. Life settlements are a rapidly growing asset category in which investors purchase life insurance policies on the secondary market with the intention of profiting by either reselling them later for a gain or holding them until maturity. One of the impediments to the development of this asset class has been the uncertainty of the U.S. federal income taxation in this area because most of the cases and rulings predate the development of an active secondary market for life insurance policies.