Taxation of Life Settlements for Policyholders and Investors: An Updated Primer

Abstract

The taxation of life insurance is a subject encompassing a wide range of lengthy and complicated tax rules. Life settlements add an additional layer of difficulty. This article provides a basic primer on the U.S. income taxation of life settlements from the perspective of both the original policyholder who sells a life insurance policy in a life settlement transaction and the investor who purchases a life insurance policy, either from its original policyholder or from another secondary life insurance market owner of the policy. Two recent revenue rulings issued by the Internal Revenue Service (IRS) both complicate and simplify this topic.