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FROM THE OFFICE OF PUBLIC AFFAIRS

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July 12, 2004
JS-1780

Treasury and IRS Issue Guidance on Source of Income
from Life Insurance and Annuities

Today, the Treasury Department and the Internal Revenue Service issued guidance on the source of income received by foreign persons and residents of Puerto Rico from life insurance and annuity contracts issued by U.S. companies.

Certain payments received under an annuity contract and amounts withdrawn from the cash value of a life insurance contract give rise to income to the recipient.  Income with respect to a contract issued by a U.S. life insurance company constitutes U.S.-source income, without regard to whether the contract is issued by a foreign or Puerto Rican branch of the U.S. insurance company.  Thus, the Revenue Ruling holds that a foreign person or Puerto Rican resident who receives income in the form of payments or withdrawals from a life insurance or annuity contract issued by a foreign or Puerto Rican branch of a U.S. life insurance company is subject to U.S. tax on such income.

 

 

 

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