2023-18193. 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.

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 www.regulations.gov (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 [e-mail] (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 [e-mail] 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 [e-mail] 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 [e-mail] 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 [e-mail] 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 [e-mail] (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 [e-mail].

Oluwafunmilayo A. Taylor,

Branch Chief, Publications and Regulations Branch, Associate Chief Counsel (Procedure and Administration).