If the IRS rules against the Structured Sale, what would happen to existing accounts?
When the IRS makes changes to tax laws, tax strategies that were executed prior to the new laws being enacted are typically not affected by the new rulings. So, the structured sale should continue to receive the same beneficial tax treatment. This has occurred many times over the years, most recently in 2006 when the IRS proposed legislation affecting Private Annuity Trusts (PATs). All properly implemented PATs established before 10/18/2006 were unaffected.
