Priv. Ltr. Rul. 201124008 (Mar. 16, 2011)

(I.R.C. §72(u) limit disallowing deferral of income tax for qualified annuities owned by a trust inapplicable when trust utilized as an agent for a natural person; under facts of ruling, trust bought annuities and remaindermen were annuitants with third person as current beneficiary of trust; distributions made from annuity before death of current beneficiary payable to trust and remaindermen after current beneficiary’s death; current situation did not involve funding of deferred compensation for employees (for which purpose  I.R.C. §72(u) was enacted to disallow deferral); all beneficiaries of trust were natural persons; distribution of annuity contracts to remaindermen not subject to deemed sale provisions of I.R.C. §72(e)(4)(C) because tax deferral would not last beyond life of any individual taxpayer).