Sec. 1.461-6 Economic performance when certain liabilities are assigned or are extinguished by the establishment of a fund.
(a) Qualified assignments of certain personal injury liabilities under section 130.
In the case of a qualified assignment (within the meaning of section 130(c)), economic performance occurs as a taxpayer-assignor makes payments that are excludible from the income of the assignee under section 130(a).
Economic performance occurs as a taxpayer makes qualified payments to a designated settlement fund under section 468B, 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 paragraph (a) of this section apply to payments after July 18, 1984.
[T.D. 8408, 57 FR 12411-12428, Apr. 10, 1992]