Private Annuity Regs

Andrew M. Katzenstein, a partner in the Los Angeles office of Katten Muchin Rosenman LLP, reports: Changes proposed to regulations (Treasury Regulations Sections 1.72 and 1.1001-1(j)) governing the income taxation of private annuity sales substantially limit the ability to accomplish income tax savings using that technique. Estate tax advantages of private annuity sales remain, but must be reconsidered