IRS Seeks Comments on Transfer for Value (aka “Reportable Policy Sale”) Rules

In March 2019, the IRS released proposed regulations for “Information Reporting for Certain Life Insurance Contract Transactions and Modifications to the Transfer for Valuable Consideration Rules.” The comment period extended to May 9, 2019.

Through our external counsel, Davis & Harman, we submitted a comment letter to the IRS seeking additional clarifications with respect to 1) BOLI Pooling Transactions; and 2) IRC § 1035 Exchanges.