EFTA01469000Set 10
17p4,605w
inclusion of the PPVA in the estate. To the extent paid to a tax-exempt
entity, the investment
income and gains within a PPVA will not be subject to income ... taxed to the estate.
If the charity or
foundation qualifies as a tax-exempt entity, such income would also not be
taxable to the taxexempt
entity.
1. Inclusions of Annuity ... explicitly state this, if the charity meets
the requirements of a tax-exempt entity such
income should not be taxable to the charity.
27 P.L.R
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01469000.pdf