§453 · Structured Installment Sale Minimum

What is the minimum for a structured installment sale?

The minimum is set by the insurer, per structure, and it applies to the amount you structure, not your sale price. As of September 2026, Corebridge Financial funds structures from $100,000 and MetLife from $500,000 (MetLife sometimes grants exceptions). If you split the deferred amount into several structures, each piece must clear its own insurer's minimum.

§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.

What are the current minimums?

In a structured installment sale, the buyer pays the full price at closing, and the deferred portion goes to an assignment company that buys a fixed annuity from its affiliated insurer to fund your payments. The insurer decides the smallest annuity it will issue for that purpose.

InsurerMinimum per structure (as of September 2026)Notes
Corebridge Financial (annuity issued by American General Life Insurance Company)$100,000Applies to each structure placed
MetLife$500,000Exceptions are sometimes granted case by case

Minimums change. Confirm the current figure when you request a quote, and check both the assignment company and the insurer named in the documents before you sign.

Does the minimum apply to the sale price or the structured amount?

The structured amount. A $3,000,000 sale where you take $2,900,000 in cash and structure $100,000 clears the Corebridge Financial minimum. A $400,000 sale where you structure all $400,000 does not clear MetLife's $500,000 minimum without an exception.

Three rules follow:

  • Cash at closing does not count. Only the dollars routed to the assignment company at closing count toward the minimum.
  • Each piece stands alone. If you want one structure paying monthly for 10 years and a second paying a lump sum in year 15, each must meet its insurer's minimum. Two $75,000 pieces at Corebridge Financial do not work; one $150,000 piece does.
  • Splitting across insurers multiplies the floor. Structuring $600,000 as $500,000 at MetLife plus $100,000 at Corebridge Financial clears both. Structuring $550,000 as $275,000 at each does not, because the MetLife piece falls short.
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.

See how splitting a sale works for the tax side.

When does a smaller deal still make sense?

Clearing the minimum is the easy part. The real question is whether spreading the gain saves enough tax to justify locking the money up. That depends on the size of the gain relative to your other income, not on the sale price.

Spreading helps when a lump-sum year would push your gain into the 20% bracket, over the 3.8% net investment income tax threshold (IRC §1411; $250,000 MAGI married filing jointly), or into a Medicare premium surcharge. It helps little when your gain already sits inside the 15% bracket every year either way.

What does that look like with real numbers?

Illustrative only. Married filing jointly, $150,000 of other taxable income each year, long-term gain only, no recapture, interest on the payments ignored. Federal tax uses 2026 married-filing-jointly brackets (Rev. Proc. 2025-32) plus NIIT; state tax extra.

ScenarioGain taxed in one yearGain spread evenlyFederal saving from spreading
Small: $90,000 of gain, spread over 5 yearsAbout $13,500 (all at 15%; MAGI stays under $250,000)About $2,700 a year, $13,500 totalAbout $0
Larger: $600,000 of gain, spread over 10 yearsAbout $115,800 (part at 20%, plus NIIT)About $9,000 a year, $90,000 totalAbout $25,800

In the small case the gain lands in the 15% bracket whether you take it now or over five years, so a structure buys almost nothing except a fixed income stream. In the larger case, a lump sum pushes $136,300 of gain into the 20% bracket and adds NIIT; spreading keeps every year at 15% and under the NIIT threshold.

The flip side also matters: a seller with low other income and a modest gain can sometimes push much of the gain into the 0% bracket (up to $98,900 of taxable income in 2026) by spreading it. In that case a small structure can earn its keep. Run your own numbers before deciding.

Remember what you give up: the structured money cannot be accelerated, borrowed against or cashed out, and interest on the payments is ordinary income. If the saving is small, keeping the cash may be the better call. See should I just pay the tax?

Frequently asked

Q: Can I do a structured installment sale on a $150,000 sale? A: It can clear Corebridge Financial's $100,000 minimum if you structure at least $100,000. Whether it is worth doing depends on how much tax spreading the gain saves at your income level.

Q: Does MetLife ever go below $500,000? A: MetLife sometimes grants exceptions, decided case by case. Do not plan on one until it is confirmed in writing with the quote.

Q: If I split into two structures, does each need to meet the minimum? A: Yes. Each structure is its own annuity, and each must clear its insurer's minimum on its own.

Q: Is there a maximum? A: Insurers set their own capacity limits, so very large amounts are quoted case by case. Separately, structured face amounts over $5,000,000 can trigger the §453A interest charge on deferred tax; see the §453A interest charge.

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

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

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