26 C.F.R. § 1.461-6   Economic performance when certain liabilities are assigned or are extinguished by the establishment of a fund.


Title 26 - Internal Revenue


Title 26: Internal Revenue
PART 1—INCOME TAXES
taxable year for which deductions taken

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§ 1.461-6   Economic performance when certain liabilities are assigned or are extinguished by the establishment of a fund.

(a) Qualified assignments of certain personal injury liabilities under section 130. In the case of a qualified assignment (within the meaning of section 130(c)), economic performance occurs as a taxpayer-assignor makes payments that are excludible from the income of the assignee under section 130(a).

(b) Section 468B. Economic performance occurs as a taxpayer makes qualified payments to a designated settlement fund under section 468B, relating to special rules for designated settlement funds.

(c) Payments to other funds or persons that constitute economic performance. [Reserved]

(d) Effective dates. The rules in paragraph (a) of this section apply to payments after July 18, 1984.

[T.D. 8408, 57 FR 12428, Apr. 10, 1992]

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