TRANSFER FOR VALUE TAX CHANGES – FINAL REGULATION

The Tax Cuts and Jobs Act of 2017 (the “TCJA”) modified the prior-law exceptions of the Transfer for Value rules (“TFV Rules”) to include a new reportable policy sale (“RPS”) requirement that is applicable to all transfers for valuable consideration. Prior to the TCJA, two critical exemptions to the TFV Rules excluded certain transactions involving life insurance contracts. Critically, these two exemptions generally shielded COLI/BOLI policies acquired during ordinary-course mergers and acquisitions (“Ordinary Course Transactions”) from the TFV Rules’ tax burden. In March, Treasury and

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