[Federal Register Volume 88, Number 163 (Thursday, August 24, 2023)]
[Proposed Rules]
[Page 57916]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[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 
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 <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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