Treasury Department, Internal Revenue Service
This document contains final regulations providing guidance on the application of the transfer for valuable consideration rules and associated information reporting requirements for reportable policy sales of interests in life insurance contracts to exchanges of life insurance contracts qualifying for nonrecognition of gain or loss and certain acquisitions of interests in life insurance contracts in transactions that qualify as corporate reorganizations. The final regulations affect parties involved in these life insurance contract transactions, including with respect to payments of reportable death benefits.
Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file number the RIN which identifies each regulatory action listed in the Unified Agenda of Federal Regulatory and Deregulatory Actions See the Document Drafting Handbook for more details. Department of the Treasury Internal Revenue Service 26 CFR Part 1 [TD 10052] RIN 1545-BQ07 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final rule. SUMMARY: This document contains final regulations providing guidance on the application of the transfer for valuable consideration rules and associated information reporting requirements for reportable policy sales of interests in life insurance contracts to exchanges of life insurance contracts qualifying for nonrecognition of gain or loss and certain acquisitions of interests in life insurance contracts in transactions that qualify as corporate reorganizations. The final regulations affect parties involved in these life insurance contract transactions, including with respect to payments of reportable death benefits. DATES: Effective date: These regulations are effective on July 9, 2026. Applicability dates: For dates of applicability, see §§ 1.101-6 and 1.6050Y-1(b). FOR FURTHER INFORMATION CONTACT: Allan H. Sakaue, (202) 317-6995 (not a toll-free number). SUPPLEMENTARY INFORMATION: Authority This document contains amendments to 26 CFR part 1 under sections 101 and 6050Y of the Internal Revenue Code (Code) issued pursuant to the express delegations of authority to the Secretary of the Treasury or his delegate (Secretary) provided under sections 6050Y(a) through (c), and 7805(a) of the Code (final regulations). Section 6050Y provides express delegations of authority to the Secretary to prescribe the …
Citation: 91 FR 42345
