Statutory Guidelines [Appendix A(3) IRC 130] regarding certain personal injury liability assignments.
District of Columbia Certain Personal Injury Liability Assignments IRS Code 130
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The Section 130 and Section 13U tax incentive regimes have been popular among those looking to establish family office structures in Singapore. Under those regimes, a single family office (SFO) providing services to the wealth structure of only one family can be exempt from regulation.
Section 130(c) defines a qualified assignment as any assignment of liability to make periodic payments as damages (whether by suit or agreement) on account of personal injury or sickness (in a case involving physical injury or sickness) provided, among other conditions, the periodic payments are fixed and determinable ...
Such periodic payments are excludable from the gross income of the recipient under paragraph (1) or (2) of section 104(a).
For purposes of this section, the term ?qualified funding asset? means any annuity contract issued by a company licensed to do business as an insurance company under the laws of any State, or any obligation of the United States, if? 130(d)(1)
