621 
sequent taxable years, such amendments shall be applied 
with respect to such unpaid losses and expenses unpaid 
by using the interest rate and loss payment patterns appli-
cable to accident years ending with calendar year 2015. 
SEC. 3511. REPEAL OF SPECIAL ESTIMATED TAX PAY-
MENTS. 
(a) IN GENERAL.—Part III of subchapter L of chap-
ter 1 is amended by striking section 847 (and by striking 
the item relating to such section in the table of sections 
for such part). 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2014. 
SEC. 3512. CAPITALIZATION OF CERTAIN POLICY ACQUISI-
TION EXPENSES. 
(a) IN GENERAL.—Paragraph (1) of section 848(c) 
is amended by striking subparagraphs (A), (B), and (C) 
and inserting the following new subparagraphs: 
‘‘(A) 5 percent of the net premiums for 
such taxable year on specified insurance con-
tracts which are group contracts, and 
‘‘(B) 12 percent of the net premiums for 
such taxable year on specified insurance con-
tracts not described in subparagraph (A).’’. 
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(b) GROUP CONTRACTS.—So much of paragraph (2) 
of section 848(e) as precedes subparagraph (A) thereof is 
amended to read as follows: 
‘‘(2) GROUP CONTRACT.—The term ‘group con-
tract’ means any specified insurance contract—’’. 
(c) CONFORMING AMENDMENTS.—Section 848(e) is 
amended by striking paragraphs (3) and (6) and by redes-
ignating paragraphs (4) and (5) as paragraphs (3) and 
(4), respectively. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2014. 
SEC. 3513. TAX REPORTING FOR LIFE SETTLEMENT TRANS-
ACTIONS. 
(a) IN GENERAL.—Subpart B of part III of sub-
chapter A of chapter 61 is amended by adding at the end 
the following new section: 
‘‘SEC. 6050X. RETURNS RELATING TO CERTAIN LIFE INSUR-
ANCE CONTRACT TRANSACTIONS. 
‘‘(a) REQUIREMENT
OF REPORTING
OF CERTAIN 
PAYMENTS.— 
‘‘(1) IN GENERAL.—Every person who acquires 
a life insurance contract or any interest in a life in-
surance contract in a reportable policy sale during 
any taxable year shall make a return for such tax-
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able year (at such time and in such manner as the 
Secretary shall prescribe) setting forth— 
‘‘(A) the name, address, and TIN of such 
person, 
‘‘(B) the name, address, and TIN of each 
recipient of payment in the reportable policy 
sale, 
‘‘(C) the date of such sale, 
‘‘(D) the name of the issuer of the life in-
surance contract sold and the policy number of 
such contract, and 
‘‘(E) the amount of each payment. 
‘‘(2) STATEMENT TO BE FURNISHED TO PER-
SONS WITH RESPECT TO WHOM INFORMATION IS RE-
QUIRED.—Every person required to make a return 
under this subsection shall furnish to each person 
whose name is required to be set forth in such re-
turn a written statement showing— 
‘‘(A) the name, address, and phone num-
ber of the information contact of the person re-
quired to make such return, and 
‘‘(B) the information required to be shown 
on such return with respect to such person, ex-
cept that in the case of an issuer of a life insur-
ance contract, such statement is not required to 
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include the information specified in paragraph 
(1)(E). 
‘‘(b) REQUIREMENT OF REPORTING OF SELLER’S 
BASIS IN LIFE INSURANCE CONTRACTS.— 
‘‘(1) IN GENERAL.—Upon receipt of the state-
ment required under subsection (a)(2) or upon no-
tice of a transfer of a life insurance contract to a 
foreign person, each issuer of a life insurance con-
tract shall make a return (at such time and in such 
manner as the Secretary shall prescribe) setting 
forth— 
‘‘(A) the name, address, and TIN of the 
seller who transfers any interest in such con-
tract in such sale, 
‘‘(B) the investment in the contract (as de-
fined in section 72(e)(6)) with respect to such 
seller, and 
‘‘(C) the policy number of such contract. 
‘‘(2) STATEMENT TO BE FURNISHED TO PER-
SONS WITH RESPECT TO WHOM INFORMATION IS RE-
QUIRED.—Every person required to make a return 
under this subsection shall furnish to each person 
whose name is required to be set forth in such re-
turn a written statement showing— 
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‘‘(A) the name, address, and phone num-
ber of the information contact of the person re-
quired to make such return, and 
‘‘(B) the information required to be shown 
on such return with respect to each seller whose 
name is required to be set forth in such return. 
‘‘(c) REQUIREMENT OF REPORTING WITH RESPECT 
TO REPORTABLE DEATH BENEFITS.— 
‘‘(1) IN GENERAL.—Every person who makes a 
payment of reportable death benefits during any tax-
able year shall make a return for such taxable year 
(at such time and in such manner as the Secretary 
shall prescribe) setting forth— 
‘‘(A) the name, address, and TIN of the 
person making such payment, 
‘‘(B) the name, address, and TIN of each 
recipient of such payment, 
‘‘(C) the date of each such payment, and 
‘‘(D) the amount of each such payment. 
‘‘(2) STATEMENT TO BE FURNISHED TO PER-
SONS WITH RESPECT TO WHOM INFORMATION IS RE-
QUIRED.—Every person required to make a return 
under this subsection shall furnish to each person 
whose name is required to be set forth in such re-
turn a written statement showing— 
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‘‘(A) the name, address, and phone num-
ber of the information contact of the person re-
quired to make such return, and 
‘‘(B) the information required to be shown 
on such return with respect to each recipient of 
payment whose name is required to be set forth 
in such return. 
‘‘(d) DEFINITIONS.—For purposes of this section: 
‘‘(1) PAYMENT.—The term ‘payment’ means 
the amount of cash and the fair market value of any 
consideration transferred in a reportable policy sale. 
‘‘(2) REPORTABLE
POLICY
SALE.—The term 
‘reportable policy sale’ has the meaning given such 
term in section 101(a)(3)(B). 
‘‘(3) ISSUER.—The term ‘issuer’ means any life 
insurance company that bears the risk with respect 
to a life insurance contract on the date any return 
or statement is required to be made under this sec-
tion. 
‘‘(4) REPORTABLE
DEATH
BENEFITS.—The 
term ‘reportable death benefits’ means amounts paid 
by reason of the death of the insured under a life 
insurance contract that has been transferred in a re-
portable policy sale.’’. 
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