ARTICLE · 31 AUGUST 2009

Certain Taxation Issues Relating To Life Insurance Settlements

Dorsey & Whitney LLP

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Tax considerations determine the structure of paper backed by life insurance settlements (“LIS”).

United StatesInsurance

Thomas Gallagher

Jonathan Ross

This article was originally published in the August 2009 Life Settlements Review

Tax considerations determine the structure of paper backed by life insurance settlements ("LIS"). From an offshore perspective, double taxation treaties ("DTTs") exist between the United States of America ("US") and a number of offshore jurisdictions. From an onshore perspective, in addition to domestic US taxation rules, which are generally beyond the scope of this paper, it is important to consider the Internal Revenue Service ("IRS") rulings relating to LIS. One of the IRS rulings includes references to non-US persons and accordingly may impact DTT protections from which investors in LIS funds benefit.

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