Regulatory Authorities Governing the SIS
Every Code section, regulation, ruling, PLR, and case that establishes, supports, and constrains the Structured Installment Sale — with the citation, what it says, and how it applies.
A Structured Installment Sale is not a creature of any single statute. It is an installment sale under IRC §453 in which the buyer's deferred-payment obligation is assigned, at or before closing, to a third-party assignment company that funds the payment stream with an annuity. Its legal validity rests on three independent pillars, each governed by its own body of authority. For each authority below you'll find the citation, what it says, and how it applies to the SIS.
| Pillar | Question it answers | Primary authorities |
|---|---|---|
| 1 · Installment treatment | Does the sale qualify to spread gain over the years payments are received? | IRC §453 (incl. §453(f)(3)); Reg. §15a.453-1; §453A; §453B |
| 2 · The obligor substitution | Can the buyer be released and a new obligor substituted without triggering gain? | IRC §453B; Rev. Rul. 75-457; Rev. Rul. 82-122; Cunningham |
| 3 · No constructive receipt | Has the seller avoided being treated as already in receipt of the money? | Reg. §1.451-2; Oden; Williams |
This catalog is organized by source type — statute → regulation → ruling → PLR → case → current enforcement — then mapped back to these three pillars in the master tables of Part 8. Educational reference only — not tax or legal advice. Authorities should be read in full and applied to specific facts by qualified tax counsel; PLRs may not be cited as precedent under §6110(k)(3). Law and rate figures reflect June 2026.
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