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
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).
(b) .
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.
(d) Effective dates.
The rules in paragraph (a) of this section apply to payments after July 18, 1984.