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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A qualified assignment is a formal arrangement wherein a defendant or its insurance company or other representative agrees to transfer their obligation to make future periodic payments to a third party (?an assignment company?). This is generally done using a uniform qualified assignment (?UQA?) document.
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).
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.
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)