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TREASURY REGULATIONS


Index  » Subchapter A  » Reg. 1.461-6

Reg. 1.461-6
Economic performance when certain liabilities are assigned or are extinguished by the establishment of a fund

January 14, 2024


§ 1.461-5 « Browse » § 1.465-1T

See related I.R.C. 461

Treas. Reg. § 1.461-6.  Economic performance when certain liabilities are assigned or are extinguished by the establishment of a fund

(a) Qualified assignments of certain personal injury liabilities under section 130. In the case of a qualified assignment (within the meaning of section 130(c)), economic performance occurs as a taxpayer-assignor makes payments that are excludible from the income of the assignee under section 130(a).

(b) Section 468B. Economic performance occurs as a taxpayer makes qualified payments to a designated settlement fund under section 468B, relating to special rules for designated settlement funds.

(c) Payments to other funds or persons that constitute economic performance. [Reserved]

(d) Effective dates. The rules in paragraph (a) of this section apply to payments after July 18, 1984.


[T.D. 8408, 57 FR 12428, Apr. 10, 1992]
 

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