Federal Tax Issues of Employee Plan and Commercial Annuities (Portfolio 821)

Description

Bloomberg Tax Portfolio, Federal Tax Issues of Employee Plan and Commercial Annuities, No. 821, explores the federal estate, income, gift, and generation-skipping transfer tax aspects of employee plan and commercial annuities.

The term “annuity” broadly refers to all periodic payments resulting from the systematic liquidation of a principal sum. This Portfolio focuses upon the application of §2039 and other federal estate tax sections to the transfer of interests in employee plan and commercial annuities at death. The analysis then shifts to a review of the income tax aspects of annuities. This Portfolio then applies the federal gift tax sections to the inter vivos transfers of these types of annuity interests followed by a discussion of the generation skipping-transfer tax implications. This Portfolio concludes with planning considerations.

For a discussion of the taxation of private annuities, see 805 T.M., Private Annuities and Self-Canceling Installment Notes. For a discussion of related transfer tax issues for interests in employee plans, see 814 T.M., Estate and Gift Tax Issues for Employee Benefit Plans. See also 546 T.M., Annuities, Life Insurance, and Long-Term Care Insurance Products (U.S. Income Series), for an analysis of the federal income taxation of non-qualified annuities, life insurance products, pre-1985 flexible premium contracts, corporate-owned life insurance, modified endowment contracts, modified guaranteed contracts, and qualified long-term care insurance.

This Portfolio may be cited as Wojnaroski, Jr., 821 T.M., Federal Tax Issues of Employee Plan and Commercial Annuities.

Table of Contents

I. Foundation
II. Federal Estate Tax
III. Income Tax Considerations
IV. Federal Gift Tax
V. Generation-Skipping Transfer Tax
VI. Planning Considerations