IRS PLR: Reinsurance of Life Insurance Contracts Won’t Constitute Material Change (IRC §101)

A financial services holding company’s reinsurance of certain life insurance contracts won’t constitute a material change to the contracts and won’t affect the date they were issued or entered into, the IRS ruled. In a reinsurance transaction, the reinsurer will assume all obligations under the policies, excepting certain limited retained liabilities described therein and, except for the change in insurer, the policies will be the same as originally, the IRS said in its analysis. [PLR 202018003]

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