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How long has the law supporting this plan been in existence and why haven’t I heard about it before? |
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This plan is based on the Internal Revenue Code, Treasury Regulations, Revenue Rulings, Tax Court and Supreme Court opinions that have been in existence for over a decade. The CHIRA® program also relies upon a recently issued private letter ruling by the U.S. Department of Treasury stating that the transaction does not violate tax rules prohibiting certain transactions between plans and certain parties and rules prohibiting investments in insurance. Private letter rulings are addressed only to the parties requesting the ruling, and such rulings may not be used by others as binding precedent. Nevertheless, a private letter ruling may be cited by another taxpayer as “substantial authority” for a tax position.
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