Private annuity trust

After October 2006 the PAT is no longer a method to defer capital gains taxes. Allstate Insurance developed the structured sale which uses a structured annuity. The structured sale (ensured installment sale) has generally been considered to be a much superior tax deferral method to the PAT. However, this is heavily debated by E. Anthony Reguero, who contends that if used properly, the private annuity trust is superior to the structured sale both in terms of the tax benefits to the beneficiary or client as well as the number of ways the IRS can benefit by taxing the trust. ==Alternatives==

Following changes to the tax treatment of private annuities, several other transactions based on installment sale law have become increasingly popular. These have included: structured sales, installment sales trusts, deferred sales trusts, and monetized installment sale. Monetized installment sales have been used by several public companies to help defer recognition of capital gains while monetizing the value of the appreciated assets they have sold. ==Notes==