NQ Transfer Annuity to SPWL

I have an individual that I'm talking to about single premium life. They have an indexed annuity that is NQ and has had it for about 8 years. We have been discussing transferring the annuity to a single premium life policy. So, in doing my own research on what kind of taxation is involved in this type of transfer I'm unsure on some things. Seems every where I've looked you don't really get an exact answer.

Will the gain be taxed as normal income under current tax bracket AND capital gains tax? Gain, taxed as normal income only or capital gain tax only?

Here is the details: Annuity
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