26 CFR 1.461-6 – Economic performance when certain liabilities are assigned or are extinguished by the establishment of a fund
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(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.