I was posed the following questions. Although it’s not IRA specific I am hoping someone with life insurance and/or annuity knowledge could weigh in.

Thank you in advance,
Brian

FACTS/QUESTIONS
If a client owns a Life Insurance Policy with cash value and has his son as the Insured, can he tax free 1035 exchange it into an Annuity with the client as owner and annuitant?

Basically, you are going from a life insurance policy for which “A” is the owner and “B” is the insured to an annuity for which “A” is the owner and “A” is the annuitant. The IRS refers to the situation that the “Obligee” must be the same on both sides of the transaction, but it is unclear as to whom the Obligee is on the annuity side.

I have heard of an IRS rev. regulation or Private Letter Ruling from 2003 that says the oblige on an annuity is deemed to be the owner, but I can’T seem locate it