Rev. rul. 2003-76

From: United States. Internal Revenue Bulletin | Date: August 18, 2003| Author: | Copyright information

ISSUES

Under the facts stated below, is a direct transfer of a portion of the cash surrender value of an existing annuity contract for a new annuity contract issued by a second insurance company a tax-free exchange under [sec] 1035 of the Internal Revenue Code? What is the basis under [sec] 1035 and the investment in the existing contract under [sec] 72 after the transfer? What is the basis under [sec] 1035 and the investment in the new annuity contract under [sec] 72?

FACTS

A owns Contract B, an annuity contract issued by Company B. A is the obligee under Contract B. A contracts with ...

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