§453 · Structured Installment Sale Interest Rate

What interest rate does a structured installment sale pay, and how is it set?

The insurer sets it from its current pricing on the day the annuity is bought, at closing. The rate depends on how long the payments are deferred, when they start and their pattern. Once funded, it is locked and does not float. You do not negotiate it, but you can compare insurers. The interest portion of each payment is ordinary income.

§453 Mechanic: How the Money Flows

Buyer cash → Assignment Co. → fixed annuity → You, on schedule

BUYER pays full cash at closing ASSIGNMENT CO. owes you the payments purchases annuity LIFE INSURER Fixed annuity from a highly rated life insurer owned by the assignment co. SELLER (you) paid on chosen 5-30 yr schedule Closing day: one wire, one assignment Gain recognized proportionally each year per IRC §453 (Treas. Reg. §15A.453-1)

Hans Goldstein structures installment sales for sellers and works alongside their CPAs. Email hans@goldsteinco.net or call 213-340-2018.

Who sets the rate, and what moves it?

In a structured installment sale, the assignment company takes over the buyer's obligation and buys a fixed annuity from its affiliated insurer to fund your payments. The insurer prices that annuity off its own current pricing, so the "rate" is really the relationship between the amount structured and the payments the insurer will make for it.

What moves it:

  • Market conditions on the purchase date. Pricing changes over time; the quote you get months before closing is not the final number. The rate locks when the annuity is funded.
  • Length of deferral. Longer schedules and later start dates generally change the pricing.
  • Payment pattern. Level, stepped and lump-sum schedules price differently.
  • The insurer. Each prices independently. Comparing insurers is the lever you have.
  • The commission. About 4% of the amount structured is built into the pricing. See fees.
Before you read further

What is the tax bill on your sale going to be?

Send me the sale price and rough basis. Within one business day I'll email you the actual number and the Seller's Guide to §453. If it doesn't fit your deal, I'll tell you that plainly.

No retainer · no obligation. Hans Goldstein, a licensed insurance agent (CA Insurance License #4273294), will contact you and may discuss insurance products, including annuities.

This page gives no current rate. Rates change, and any number here would be stale. Ask for a written quote close to closing.

Is the rate locked?

Yes. Once the annuity is funded, the payment schedule is fixed in the contract. If market rates rise later, your payments do not go up; if they fall, your payments do not go down. The payments depend on the claims-paying ability of the assignment company and the insurer behind it. See what if interest rates rise?

How is the interest taxed?

Each payment has three parts: basis recovery (not taxed), gain (capital gain rates, reported on Form 6252) and interest (ordinary income). The interest portion is also net investment income for the 3.8% tax under IRC §1411 if your MAGI is over the threshold ($250,000 married filing jointly, $200,000 single).

Your total payments will exceed the amount structured. Only the excess over the structured principal is interest; the rest follows the gross profit ratio.

Separately, an installment sale must carry adequate stated interest measured against the applicable federal rate. If it does not, IRC §483 or §1274 recharacterizes part of the principal as interest. Your CPA confirms the structure clears that test; it is one of the items to review before closing.

What does that look like with real numbers?

Hypothetical, not a quote. Assume the pricing worked out to an effective 4.5% and you structure $1,000,000 to pay 10 level annual payments, the first one year after closing.

Payment = $1,000,000 x 0.045 / (1 - 1.045^-10) = about $126,400 a year.

ItemAmount (illustrative)
Amount structured$1,000,000
Annual payment (10 years)About $126,400
Total of all paymentsAbout $1,263,800
Interest over the 10 yearsAbout $263,800
Principal over the 10 years$1,000,000

The interest, about $263,800 in total, is ordinary income in the years you receive it; your CPA allocates each payment between interest and principal. The $1,000,000 of principal follows your gross profit ratio: if your ratio is 60%, $600,000 of it is capital gain spread across the payments and $400,000 is basis recovery.

The 4.5% is an assumption chosen only to show the math. Your actual pricing could be higher or lower. Run your own numbers on the installment sale interest calculator.

How should you compare quotes?

  • Compare total payments for the same schedule. Same amount, same start date, same frequency, same end date across insurers.
  • Compare on a written quote, dated, showing every payment.
  • Check the insurer's current A.M. Best rating. A slightly better rate from a weaker insurer is a poor trade; look for a highly rated life insurer, A or better by A.M. Best or equivalent.
  • Think in after-tax terms. The rate is only part of the picture. The bigger number is usually the tax saved by keeping your gain out of the 20% bracket and under the NIIT threshold.

Frequently asked

Q: Can I negotiate the rate? A: No. The insurer sets it from its pricing. You can compare insurers and adjust the schedule, which changes the quote.

Q: Does the rate change after closing? A: No. It locks when the annuity is funded, and the payment schedule is fixed in the contract.

Q: Is the interest taxed differently from the gain? A: Yes. Interest is ordinary income in the year received and counts as net investment income. The gain portion gets capital gain rates under the installment method.

Q: What is the current rate? A: It changes with market pricing, so this page does not quote one. Ask for a dated written quote close to your closing date.

What should you read or run next?

Who wrote this?

About the author

Hans Goldstein works with sellers on IRC §453 installment sales. Tax and exit-planning analysis: Hans Goldstein: Tax & Exit Planning. Annuity placement for structured installment sales: Goldstein & Co. LLC dba Goldstein Insurance Services, CA ins. lic. #4273294. Hans is not a CPA or attorney, and this page is education, not tax or legal advice; have your CPA review your facts. A commission is paid only if a structured installment sale is funded.

Last updated September 30, 2026.

Talk to Hans: hans@goldsteinco.net · 213-340-2018

Hans Goldstein, NPN 20602398

Find out what your sale is really going to cost you in tax, and what you can do about it

No retainer. On a funded structure, the insurer pays a one-time commission of about 4% of the amount structured to the brokerage firm that places it (Hans’s share is about 2.4%; no trail). It is built into the annuity pricing, not a separate fee.

Send me the sale price and roughly what you paid. Within one business day I’ll come back with the number you’re actually looking at and whether a structured installment sale can push it down. If it can’t, I’ll say that just as plainly.

You'll also get the plain-English Seller's Guide to §453: the math, the alternatives, and the cases where it does not work.

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📞 Hans Goldstein · 213-340-2018 · CA Insurance License #4273294 · Independent §453 specialist · Goldstein & Co. LLC

Hans Goldstein, a licensed insurance agent (CA Insurance License #4273294), will contact you and may discuss insurance products, including annuities.

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