The memorandum discusses the U.S. federal income tax treatment of a U.S. individual owning a private placement variable annuity (PPVA). It explains the deferral of taxation on the growth in value of the investment portfolio underlying a PPVA and the tax implications upon receiving payments, surrendering the PPVA, or upon the owner's death. It also notes the tax benefits if a tax-exempt charity or private foundation is made the beneficiary.
doj/DataSet10/EFTA01454372.pdf
{"title":"U.S. Tax Treatment of Private Placement Variable Annuity","key_people":["Richard L. Reinhold","David J. McCabe","Catherine A. Harrington","Tyler H. Ladner"],"document_date":"August 2011","document_type":"correspondence","document_subtype":"memo","key_organizations":["Willkie Farr & Gallagher LLP","Winged Keel Group, Inc."],"reference_numbers":["DB-SDNY-0112438","SDNY_GM_00258622","EFTA01454372"]}