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

26 CFR § 1.461-6eCFR, current through 2026-07-14

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

(b) Section 468B Economic performance occurs as a taxpayer makes qualified payments to a designated settlement fund under section , 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 of this section apply to payments after July 18, 1984.

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