April 2020

TAX DEVELOPMENTS

IRS Private Letter Ruling on Policyholder Implications of Assumption Reinsurance Transaction

On May 1, the IRS publicly released a Private Letter Ruling (Number 202018003) stating that for purposes of sections 101(j), 264(f), 7702, and 7702A of the IRC, a reinsurance transaction will not constitute a material change of certain life insurance contracts and will not affect the date the contracts were issued or entered into.

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