The document discusses the use of PPVA (Private Placement Variable Annuity) investment accounts as a method to block Unrelated Business Taxable Income (UBTI). It explains how PPVA accounts can change the character of investments to passive income, thus avoiding UBTI. The document also highlights the IRS's favorable rulings on PPVA accounts and compares them to other UBTI blocker arrangements. It outlines the benefits of PPVA accounts, such as tax-free transfers and systematic distribution of principal, and provides guidelines for structuring customized accounts with investment managers.
doj/DataSet10/EFTA01454212.pdf
{"title":"FEATURE: INVESTMENTS","document_date":"December 2012","document_type":"other","key_organizations":["IRS"],"reference_numbers":["IRC Section 72(u)(1)","IRC Section 1035","IRC Section 817(h)"]}