Independent & Third-Party Sources · Public Citations

Don't take my word for it. Take theirs.

Mainstream CPAs, tax attorneys, insurers and household-name financial-planning publications have published on IRC §453 Structured Installment Sales, and the IRS publishes the installment-sale rules they rely on. Below are direct quotes and citations. Verify everything.

▸ Carrier perspective
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Hans Goldstein, EA
Admitted to practice before the IRS

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Life insurers and industry writers have explained this structure in print.

Insurers that issue these annuities publish educational material for their distribution channels, and they have a commercial interest in writing the premium. That tells you the structure is real and in use; it is not a ruling. No IRS ruling specifically approves the assignment structure, so bring the citations below to your own CPA or tax attorney.

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Structured installment sales evolved as an outgrowth of IRC section 453, which governs the selling of qualifying appreciated assets using the installment method.
From an introductory article on structured installment sales in a professional CPA journal, December 2021.
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The gain is taxed as it's realized over time, rather than all at once, which can significantly affect your total tax bill.
From a CPA firm’s client guide to installment sales, December 2025.
▸ Independent financial-planning analysis

The leading fiduciary-advisor publication distinguishes the legitimate §453 structure from the risky imitation.

A widely read continuing-education publication for financial planners draws the distinction: in the §453 Structured Installment Sale, the payments are owed by an assignment company and funded by an annuity from a regulated life insurer. The "Deferred Sales Trust" version shifts the credit risk onto a private trustee with no insurer behind it. That's why the IRS scrutinizes it.

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Under IRC Sec. 453, capital gains on the sale of assets, such as privately held businesses where the payments are spread out over a period of 2 or more years, are deferred until the years when the payments are actually received.
From a financial-planning publication’s analysis of Deferred Sales Trust risks, May 2024.
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For owners of businesses and other assets, a Structured Installment Sale works similarly to a deferred sales trust in that it uses a third party to facilitate the installment agreement between the buyer and the seller, except that the third party uses the sales proceeds to fund an annuity.
Same article, May 2024. The annuity funding is what separates it from a deferred sales trust, where your payments depend on a trustee's investments. With an SIS, your payments depend on the assignment company and the insurer behind its annuity. (See also our NOT a deferred sales trust page for the regulatory contrast.)
▸ Primary sources: the IRS itself

Skip everyone's commentary and go straight to the source.

Every claim on this site reduces to one of the following. Read them yourself.

IRC §453: Installment Method The Internal Revenue Code section that authorizes installment-sale tax treatment. The legal basis of every SIS placement. Read on Cornell LII →
IRC §453A: Interest on Deferred Tax The "teeth" provision: imposes an interest charge on installment obligations outstanding above $5,000,000 at year-end. Read on Cornell LII →
Treas. Reg. §15a.453-1 The detailed regulatory framework defining "payment," eligibility, and reporting under §453. The technical basis for how SIS structures qualify for installment treatment. Read the regulation →
IRS Publication 537: Installment Sales The IRS's own taxpayer-facing publication on how to compute and report an installment sale. Print it. Bring it to your CPA. Read on irs.gov →
IRS PLRs 201248006, 201248007, 201248008 (2012) Private Letter Rulings confirming that modifying an installment obligation by deferring the maturity date, substituting a new obligor, and altering the interest rate is not a disposition under §453B, for the taxpayer who asked. A PLR binds only that taxpayer (IRC §6110(k)(3)) and does not involve an assignment company; no IRS ruling specifically approves the SIS assignment structure. PLR 201248006 (PDF)
IRS Topic 705: Installment Sales Plain-language IRS guidance on what an installment sale is, who qualifies, and the basic reporting requirements. Read on irs.gov →
About the sources cited above. The materials referenced on this page are publicly available third-party publications, regulatory citations, and carrier-distributed educational white papers. They are cited here for educational purposes only. Citing a publication on this page does not represent a partnership, agency relationship, endorsement, or producer-carrier appointment. Hans Goldstein does not currently hold direct carrier appointments for SIS placement and works through licensed co-broker arrangements. Carrier selection on any given case depends on suitability, current rates, and broker access at the time of placement. All quotes are reproduced verbatim from the source; bracketed emphasis added in some cases for readability and is noted where it occurs.

Bring this page to your CPA. Bring it to your attorney.

The structure is real, the citations are public, and the math is verifiable. If you want to talk through whether SIS fits your sale with your CPA on the line, call me.

Talk to Hans: 213-414-2808
Hans Goldstein, NPN 20602398

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Hans Goldstein, EA
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📞 Hans Goldstein · 213-414-2808 · 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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