Under Section 1035 of the Internal Revenue Code, stipulation that the exchange of one life insurance policy for another life insurance policy will generally not result in a recognized gain for the purpose of federal income tax purposes to the policy owner who exchanges the policy. The insured must be the same person under both policies. If the policy owner should surrender the second policy in a taxable transaction, the untaxed gain is then recognized. The types of policy exchanges that can be made on a tax-free basis are as follows: (1) a life insurance policy for another life insurance policy; (2) a life insurance policy for an annuity contract; and (3) an annuity contract for another annuity contract. An annuity contract cannot be exchanged on a tax-free basis for a life insurance policy. The annuitant must be the same person under both annuity contracts in order to maintain the tax-free basis.