This document discusses the U.S. federal estate tax implications of a PPVA (Private Placement Variable Annuity) upon the death of the annuitant. It explains that the value of the PPVA is included in the decedent's gross estate for tax purposes, and there is no fair market value basis step-up. It also covers the estate tax deduction available if a tax-exempt charity is the beneficiary of the PPVA, referencing several IRS private letter rulings. The opinion is limited to U.S. federal income and estate tax matters and is subject to change.
doj/DataSet10/EFTA01454378.pdf
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