May 2023


Reportable Policy Sale Proposed Update

On May 10 the IRS published a proposed rule in the Federal Register to amend the existing regulations relating to section 1035 exchanges of life insurance and certain other life insurance contract transactions. These regulations are sometimes referred to as the Reportable Policy Sale rules. The Tax Cuts and Jobs Act added IRC 101(a)(3) established the term Reportable Policy Sale which limits the applicability of the previously existing exemptions from the so-called transfer for value rules if a transfer of life insurance contracts constitutes a Reportable Policy Sale.

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