Statutory Guidelines [Appendix A(3) IRC 130] regarding certain personal injury liability assignments.
Statutory Guidelines [Appendix A(3) IRC 130] regarding certain personal injury liability assignments.
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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 ...
Any amount received for agreeing to a qualified assignment shall not be included in gross income to the extent that such amount does not exceed the aggregate cost of any qualified funding assets.
Such periodic payments are excludable from the gross income of the recipient under paragraph (1) or (2) of section 104(a).
For damages, the two most common exceptions are amounts paid for certain discrimination claims and amounts paid on account of physical injury. IRC Section 104 explains that gross income does not include damages received on account of personal physical injuries and physical injuries.
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)