SECTION 1. PURPOSE

This notice announces that the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) intend to issue proposed regulations providing guidance to assist taxpayers in complying with new information reporting obligations for certain life insurance contract transactions under § 6050Y, which was added to the Internal Revenue Code (the “Code”) by section 13520 of “[a]n Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115–97 (the “Act”). The proposed regulations also will provide guidance on a modification to the transfer for valuable consideration rules for life insurance contracts added to § 101(a) by section 13522 of the Act. This notice requests public comments on the implementation of these provisions of the Act.

This notice also provides transitional guidance under § 6050Y. Specifically, as provided in section 3.A.iv. of this notice, to ensure efficient administration of this new provision, reporting will not be required under § 6050Y until final regulations are issued. For reportable policy sales and payments of reportable death benefits occurring after December 31, 2017, and before the date final regulations

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under § 6050Y are published in the Federal Register, Treasury and the IRS intend to allow additional time after the date final regulations are published to file the returns and furnish the written statements required by § 6050Y.