Proposed Rule2023-18193
Information Reporting and Transfer for Valuable Consideration Rules for Section 1035 Exchanges of Life Insurance and Certain Other Life Insurance Contract Transactions; Hearing
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
August 24, 2023
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
This document provides a notice of public hearing on proposed 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, as well as to certain acquisitions of interests in life insurance contracts in transactions that qualify as corporate reorganizations.
Full Text
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<title>Federal Register, Volume 88 Issue 163 (Thursday, August 24, 2023)</title>
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[Federal Register Volume 88, Number 163 (Thursday, August 24, 2023)]
[Proposed Rules]
[Page 57916]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-18193]
[[Page 57916]]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-108054-21]
RIN 1545-BQ07
Information Reporting and Transfer for Valuable Consideration
Rules for Section 1035 Exchanges of Life Insurance and Certain Other
Life Insurance Contract Transactions; Hearing
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; notice of hearing.
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SUMMARY: This document provides a notice of public hearing on proposed
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, as well as to certain acquisitions of
interests in life insurance contracts in transactions that qualify as
corporate reorganizations.
DATES: The public hearing on this proposed regulation has been
scheduled for Thursday, September 28, 2023, at 10:00 a.m. ET. The IRS
must receive speakers' outlines of the topics to be discussed at the
public hearing by Wednesday, August 30, 2023. If no outlines are
received by Wednesday, August 30, 2023, the public hearing will be
cancelled.
ADDRESSES: The public hearing is being held in the Auditorium, at the
Internal Revenue Service Building, 1111 Constitution Avenue NW,
Washington, DC. Due to security procedures, visitors must enter at the
Constitution Avenue entrance. In addition, all visitors must present a
valid photo identification to enter the building. Because of access
restrictions, visitors will not be admitted beyond the immediate
entrance area more than 30 minutes before the hearing starts.
Participants may alternatively attend the public hearing by telephone.
Send submissions to CC:PA:LPD:PR (REG-108054-21), Room 5205,
Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may be hand delivered Monday through
Friday to CC:PA:LPD:PR (REG-108054-21), Couriers Desk, Internal Revenue
Service, 1111 Constitution Avenue NW, Washington, DC 20224 or sent
electronically via the Federal eRulemaking Portal at
<a href="http://www.regulations.gov">www.regulations.gov</a> (IRS REG-108054-21) (preferred).
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
Allan H. Sakaue, (202) 317-6995; concerning submissions of outlines,
the hearing, and/or to be placed on the building access list to attend
the public hearing, call Vivian Hayes (202) 317-6901 (not a toll-free
number) or by email to <a href="/cdn-cgi/l/email-protection#3a4a4f58565359525f5b4853545d497a534849145d554c"><span class="__cf_email__" data-cfemail="0a7a7f68666369626f6b7863646d794a637879246d657c">[email protected]</span></a> (preferred).
SUPPLEMENTARY INFORMATION: The subject of the public hearing is the
notice of proposed rulemaking (REG-108054-21) that was published in the
Federal Register on Wednesday, May 10, 2023, (FR 88 30058).
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who
wish to present oral comments at the hearing must submit an outline of
the topics to be discussed and the time to be devoted to each topic by
August 30, 2023.
A period of 10 minutes will be allotted to each person for making
comments. An agenda showing the scheduling of the speakers will be
prepared after the deadline for receiving outlines has passed. Copies
of the agenda will be available free of charge at the hearing, and via
the Federal eRulemaking Portal (www.Regulations.gov) under the title of
Supporting & Related Material. If no outline of the topics to be
discussed at the hearing is received by August 30, 2023, the public
hearing will be cancelled. If the public hearing is cancelled, a notice
of cancellation of the public hearing will be published in the Federal
Register.
Individuals who want to testify in person at the public hearing
must send an email to <a href="/cdn-cgi/l/email-protection#75050017191c161d1014071c1b1206351c07065b121a03"><span class="__cf_email__" data-cfemail="74040116181d171c1115061d1a1307341d06075a131b02">[email protected]</span></a> to have your name added to
the building access list. The subject line of the email must contain
the regulation number REG-108054-21 and the language TESTIFY In Person.
For example, the subject line may say: Request to TESTIFY In Person at
Hearing for REG-108054-21.
Individuals who want to testify by telephone at the public hearing
must send an email to <a href="/cdn-cgi/l/email-protection#5d2d283f31343e35383c2f34333a2e1d342f2e733a322b"><span class="__cf_email__" data-cfemail="fc8c899e90959f94999d8e95929b8fbc958e8fd29b938a">[email protected]</span></a> to receive the telephone
number and access code for the hearing. The subject line of the email
must contain the regulation number REG-108054-21 and the language
TESTIFY Telephonically. For example, the subject line may say: Request
to TESTIFY Telephonically at Hearing for REG-108054-21.
Individuals who want to attend the public hearing in person without
testifying must also send an email to <a href="/cdn-cgi/l/email-protection#bececbdcd2d7ddd6dbdfccd7d0d9cdfed7cccd90d9d1c8"><span class="__cf_email__" data-cfemail="29595c4b45404a414c485b40474e5a69405b5a074e465f">[email protected]</span></a> to have
your name added to the building access list. The subject line of the
email must contain the regulation number REG-108054-21 and the language
ATTEND In Person. For example, the subject line may say: Request to
ATTEND Hearing In Person for REG-108054-21. Requests to attend the
public hearing must be received by 5:00 p.m. ET by Monday, September
25, 2023.
Individuals who want to attend the public hearing by telephone
without testifying must also send an email to <a href="/cdn-cgi/l/email-protection#304045525c595358555142595e5743705942431e575f46"><span class="__cf_email__" data-cfemail="1c6c697e70757f74797d6e75727b6f5c756e6f327b736a">[email protected]</span></a> to
receive the telephone number and access code for the hearing. The
subject line of the email must contain the regulation number REG-
108054-21 and the language ATTEND Hearing Telephonically. For example,
the subject line may say: Request to ATTEND Hearing Telephonically for
REG-108054-21. Requests to attend the public hearing must be received
by 5:00 p.m. ET by Monday, September 25, 2023.
Hearings will be made accessible to people with disabilities. To
request special assistance during a hearing please contact the
Publications and Regulations Branch of the Office of Associate Chief
Counsel (Procedure and Administration) by sending an email to
<a href="/cdn-cgi/l/email-protection#9cece9fef0f5fff4f9fdeef5f2fbefdcf5eeefb2fbf3ea"><span class="__cf_email__" data-cfemail="6b1b1e09070208030e0a1902050c182b021918450c041d">[email protected]</span></a> (preferred) or by telephone at (202) 317-6901
(not a toll-free number) by Monday, September 25, 2023. Any questions
regarding speaking at or attending a public hearing may also be emailed
to <a href="/cdn-cgi/l/email-protection#403035222c292328252132292e2733002932336e272f36"><span class="__cf_email__" data-cfemail="e09095828c898388858192898e8793a0899293ce878f96">[email protected]</span></a>.
Oluwafunmilayo A. Taylor,
Branch Chief, Publications and Regulations Branch, Associate Chief
Counsel (Procedure and Administration).
[FR Doc. 2023-18193 Filed 8-23-23; 8:45 am]
BILLING CODE 4830-01-P
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