Opportunity

Federal Register #TD 10052

IRS Final Rule: Reporting and Transfer Rules for Life Insurance Contract Exchanges

Buyer

Internal Revenue Service

Posted

July 09, 2026

Identifier

TD 10052

This regulatory action from the Internal Revenue Service (IRS), part of the Department of the Treasury, provides final guidance on information reporting and transfer rules for certain life insurance contract transactions. - Government Buyer: - Department of the Treasury, Internal Revenue Service (IRS) - No OEMs or commercial vendors are involved, as this is not a procurement opportunity - Products/Services Requested: - No products or services are being procured; this is a regulatory update - Key Regulatory Details: - Clarifies information reporting requirements for reportable policy sales of life insurance contracts - Addresses transfer for valuable consideration rules, especially for Section 1035 exchanges and corporate reorganizations - Updates definitions and reporting obligations for parties involved in life insurance contract transactions - Impacts reporting of death benefits and nonrecognition of gain or loss in certain exchanges - No contract value, line items, or period of performance, as this is not a solicitation or award

Description

This final regulation provides guidance on the application of transfer for valuable consideration rules and associated information reporting requirements for reportable policy sales of interests in life insurance contracts. It addresses exchanges of life insurance contracts qualifying for nonrecognition of gain or loss and certain acquisitions of interests in life insurance contracts in transactions qualifying as corporate reorganizations. The regulations affect parties involved in these transactions, including with respect to payments of reportable death benefits. The rule clarifies reporting obligations and transfer rules, especially in the context of section 1035 exchanges and corporate reorganizations.

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