us-irs-announcements-irb-2020-17-pdf•Internal Revenue Bulletin 2020-17 (PDF rendition): IRS Announcements
Internal Revenue Bulletin 2020-17 (PDF rendition): IRS Announcements
us-irs-announcements-irb-2020-17-pdfInternal Revenue Bulletin 2020-17 (PDF rendition): IRS AnnouncementsGuidance
Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.
Bulletin No. 2020–17 April 20, 2020 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. ADMINISTRATIVE Action On Decision 2020-3, page 663. Acquiescence to the holding that the term “taxpayer” in sec- tion 7811 can be broadly interpreted to include a wrong- ful-levy claimant. Nonacquiescence to the holding that sec- tion 7811(d) suspends the running of the limitations periods for third-parties to file wrongful levy claims or suits. ADMINISTRATIVE & EMPLOYMENT TAX Notice 2020-22, page 664. This notice provides a waiver of additions to tax for failure to make a deposit of taxes for employers required to pay qualified sick leave wages and qualified family leave wages mandated by the Families First Coronavirus Response Act (Families First Act) and qualified health plan expenses allo- cable to these wages. This notice also provides a waiver of additions to tax for failure to make a deposit of taxes for certain employers experiencing a full or partial business suspension due to orders from a governmental authority due to the coronavirus disease 2019 or experiencing a statuto- rily specified decline in business under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). This notice applies to deposits of Employment Taxes (including withheld income taxes, taxes under the Federal Insurance Contribu- tions Act and taxes under the Railroad Retirement Act) re- duced in anticipation of the credits with respect to qualified sick leave wages and qualified family leave wages paid with respect to the period beginning April 1, 2020, and ending December 31, 2020. This notice applies with respect to deposits of Employment Taxes reduced in anticipation of the credits with respect to qualified wages paid with respect to the period beginning on March 13, 2020, and ending Decem- ber 31, 2020. ADMINISTRATIVE & SPECIAL ANNOUNCEMENT Announcement 2020-4, page 667. Announcement 2020-4 provides that public hearings on notices of proposed rulemaking will be held telephonical- ly and encourages taxpayers to submit public comments electronically. INCOME TAX REG-132529-17, page 667. The proposed regulations provide guidance on determining life insurance reserves and changing the method of com- puting certain insurance company reserves. The proposed regulations also authorize changes to insurance company reporting requirements and propose numerous conforming changes to other regulations. The proposed regulations im- plement legislative changes made by sections 13513 and 13517 of the Tax Cuts and Jobs Act. Finding Lists begin on page ii. The IRS Mission Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and en- force the law with integrity and fairness to all. Introduction The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing of- ficial rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- wise indicated. Procedures relating solely to matters of inter- nal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rul- ings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period. The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. April 20, 2020 Bulletin No. 2020–17 Actions Relating to Decisions of the Tax Court It is the policy of the Internal Reve nue Service to announce at an early date whether it will follow the holdings in cer tain cases. An Action on Decision is the document making such an announcement. An Action on Decision will be issued at the discretion of the Service only on un appealed issues decided adverse to the government. Generally, an Action on De cision is issued where its guidance would be helpful to Service personnel working with the same or similar issues. Unlike a Treasury Regulation or a Revenue Ruling, an Action on Decision is not an affirma tive statement of Service position. It is not intended to serve as public guidance and may not be cited as precedent. Actions on Decisions shall be relied upon within the Service only as conclu sions applying the law to the facts in the particular case at the time the Action on Decision was issued. Caution should be exercised in extending the recommenda tion of the Action on Decision to similar cases where the facts are different. More over, the recommendation in the Action on Decision may be superseded by new legislation, regulations, rulings, cases, or Actions on Decisions. Prior to 1991, the Service published acquiescence or nonacquiescence only in certain regular Tax Court opinions. The Service has expanded its acquiescence program to include other civil tax cases where guidance is determined to be help ful. Accordingly, the Service now may acquiesce or nonacquiesce in the holdings of memorandum Tax Court opinions, as well as those of the United States District Courts, Claims Court, and Circuit Courts of Appeal. Regardless of the court decid ing the case, the recommendation of any Action on Decision will be published in the Internal Revenue Bulletin. The recommendation in every Action on Decision will be summarized as ac quiescence, acquiescence in result only, or nonacquiescence. Both “acquiescence” and “acquiescence in result only” mean that the Service accepts the holding of the court in a case and that the Service will follow it in disposing of cases with the same controlling facts. However, “acqui escence” indicates neither approval nor disapproval of the reasons assigned by the court for its conclusions; whereas, “acqui escence in result only” indicates disagree ment or concern with some or all of those reasons. “Nonacquiescence” signifies that, although no further review was sought, the Service does not agree with the hold ing of the court and, generally, will not follow the decision in disposing of cases involving other taxpayers. In reference to an opinion of a circuit court of appeals, a “nonacquiescence” indicates that the Ser vice will not follow the holding on a na tionwide basis. However, the Service will recognize the precedential impact of the opinion on cases arising within the venue of the deciding circuit. The Commissioner does ACQUIESCE IN RESULT ONLY in the following de cision: Rothkamm v. United States, 802 F.3d 699 (5th Cir. 2015), rev’g 2014 WL 4986884 (M.D. La. Sept. 15, 2014) 1 1 Acquiescence to the holding that the term “taxpayer” in section 7811 can be broadly interpreted to include a wrongfullevy claimant. Nonacquiescence to the holding that section 7811(d) suspends the running of the limitations periods for thirdparties to file wrongful levy claims or suits. Bulletin No. 2020–17 663 April 20, 2020 Part III Relief from Penalty for Failure to Deposit Employment Taxes Notice 2020-22 SECTION 1. PURPOSE The purpose of this notice is to provide penalty relief with respect to certain em ployers’ deposits of Federal employment taxes with the Internal Revenue Service (IRS) under §§ 31.63021 or 31.63022 of the Employment Taxes and Collection of Income Tax at Source Regulations, in cluding deposits of withheld income tax es, taxes under the Federal Insurance Con tributions Act (FICA), and taxes under the Railroad Retirement Tax Act (RRTA) (collectively, Employment Taxes). Spe cifically, this notice provides relief to em ployers entitled to the new refundable tax credits provided under the Families First Coronavirus Response Act (Families First Act), Public Law No. 116127 (March 18, 2020), and the Coronavirus Aid, Re lief, and Economic Security Act (CARES Act), Public Law No. 116136 (March 27, 2020). Employers paying qualified sick leave wages and qualified family leave wages required by the Families First Act (collec tively, Qualified Leave Wages), as well as qualified health plan expenses allocable to Qualified Leave Wages (Qualified Health Plan Expenses) are eligible for refundable tax credits under the Families First Act. Additionally, certain employers experi encing a full or partial business suspen sion due to orders from a governmental authority due to the coronavirus disease 2019 (COVID19) or experiencing a statu torily specified decline in business are also allowed a refundable tax credit under the CARES Act of up to fifty percent of the qualified wages, including allocable qualified health expenses and limited to $10,000 per employee over all calendar quarters combined (Qualified Retention Wages). Under the Families First Act and the CARES Act, an employer paying Qualified Leave Wages or Qualified Re tention Wages may take refundable tax credits against a specified portion of the employer’s share of certain Employment Taxes. Section 3 of this notice provides em ployers relief from the failure to depos it penalty imposed by section 6656 of the Internal Revenue Code (Code) for an employer’s failure to timely depos it Employment Taxes to the extent that the amounts not deposited are equal to or less than the amount of refundable tax credits to which the employer is en titled under the Families First Act and the CARES Act. This relief ensures that such employers may pay Qualified Leave Wages required by the Families First Act or Qualified Retention Wages under the CARES Act using Employment Taxes that would otherwise be required to be deposited without incurring a failure to deposit penalty. This notice applies to deposits of Employment Taxes reduced in anticipation of the credits with respect to Qualified Leave Wages paid with re spect to the period beginning April 1, 2020, and ending December 31, 2020, and in anticipation of the credits with re spect to Qualified Retention Wages paid with respect to the period beginning on March 13, 2020, and ending December 31, 2020. SECTION 2. BACKGROUND Section 3111(a) of the Code (employ er’s share of the Old Age, Survivors, and Disability Insurance (social security) por tion of FICA tax) and section 3221(a) of the Code (employer’s share of the social security and Hospital Insurance (Medi care) portions of RRTA tax), along with section 3402 related to Federal income tax withholding, impose Employment Tax lia bility on employers. For most employers, this liability is reported on the quarterly Form 941, Employer’s QUARTERLY Federal Tax Return. Section 2302 of the CARES Act pro vides that the payment and deposit of the employer’s share of the social security portion of FICA tax and the employ er’s share of the social security portion of RRTA tax for deposits that are due to be made during the period beginning on March 27, 2020, and ending before Janu ary 1, 2021, is not due before December 31, 2021 (for the first 50 percent of the liability), and December 31, 2022 (for the remaining 50 percent of the liabili ty). Under this provision, an employer is treated as having timely made these re quired deposits of FICA and RRTA tax es if all such deposits are made not later than the applicable due dates. This defer ral of payment does not apply to employ ers that have had indebtedness forgiven under either section 1106 or 1109 of the CARES Act. Although Form 941 is due quarterly and payment and deposit of certain FICA (and RRTA) taxes is deferred under sec tion 2302 of the CARES Act, section 6302 of the Code and regulations under that section generally require deposits of Em ployment Taxes to be made on a monthly or biweekly basis. Employers that accu mulate $100,000 or more of Employment Taxes on any day within a deposit period are required to deposit those liabilities with the IRS the next banking day. See § 31.63021(c). The Families First Act generally re quires employers of fewer than 500 em ployees to provide paid sick leave and expanded family and medical leave, up to specified limits, to employees unable to work or telework due to certain circum stances related to COVID19. Generally, employers that are required to pay Quali fied Leave Wages under the Families First Act are entitled to refundable tax credits administered by the IRS. (The govern ment of the United States, the government of any State or political subdivision there of, or any agency or instrumentality of the foregoing is not entitled to these refund able tax credits.) Sections 7001 and 7003 of the Families First Act provide a refundable tax credit against an employer’s share of the social security portion of FICA tax and an em ployer’s share of the social security and Medicare portions of RRTA tax for each calendar quarter in an amount equal to 100 percent of Qualified Leave Wages paid by the employer plus Qualified Health Plan Expenses with respect to that calendar April 20, 2020 664 Bulletin No. 2020–17 Bulletin No. 2020–17 665 April 20, 2020 quarter. (For purposes of this notice, an employer’s share of the social security portion of FICA tax and an employer’s share of the social security and Medicare portions of RRTA tax, as applicable, are referred to as, Creditable Employment Taxes.) For employers subject to FICA tax, the credits under section 7001 and 7003 are increased by the amount of the employer’s share of Medicare tax imposed on Qualified Leave Wages. . See section 7005(b)(1) of the Families First Act. (For purposes of this notice, the increase in credit under section 7005(b)(1) is treated as a credit under section 7001 or section 7003.) The refundable tax credit is report ed on the employer’s return for reporting its liability for FICA tax or RRTA tax, as applicable, which for most employers subject to FICA tax is the quarterly Form 941. An employer may claim an advance payment of the refundable tax credits by filing Form 7200, Advance Payment of Employer Credits Due to COVID19. Section 2301 of the CARES Act pro vides a refundable tax credit against an employer’s Creditable Employment Taxes for each calendar quarter for Qualified Re tention Wages paid by the employer. The refundable tax credit is reported on the employer’s return for reporting its liability for FICA tax or RRTA tax, as applicable, which for most employers subject to FICA tax is the quarterly Form 941. An employer may claim an advance payment of the re fundable tax credit for Qualified Retention Wages under section 2301 of the CARES Act by filing Form 7200, Advance Payment of Employer Credits Due to COVID19. Section 6656 of the Code imposes a penalty for any failure to deposit amounts as required by the Code or regulations on the date prescribed therefor, unless such failure is due to reasonable cause and not due to willful neglect. A failure to deposit taxes as required under section 6302 of the Code would generally subject an employ er to the section 6656 penalty. Sections 7001(i) and 7003(i) of the Families First Act, as added by section 3606(a) and (c) of the CARES Act, and section 2301(k) of the CARES Act, in struct the Secretary of the Treasury (or the Secretary’s delegate) to waive the penalty under section 6656 of the Code for failure to deposit the employer share of social se curity tax in anticipation of the allowance of the refundable tax credits allowed un der the Families First Act and the CARES Act. Furthermore, sections 7001(f) and 7003(f) of the Families First Act specif ically authorize guidance providing for waiver of penalties for failure to deposit amounts in anticipation of the allowance of the credits provided by the Families First Act. Section 3 of this notice provides relief from the penalty under section 6656 pursuant to the Families First Act and the CARES Act. SECTION 3. RELIEF FROM FAILURE TO MAKE A DEPOSIT OF TAXES a. Employment Taxes Related to Quali- fied Leave Wages An employer will not be subject to a penalty under section 6656 for failing to deposit Employment Taxes relating to Qualified Leave Wages in a calendar quar ter if— (1) The employer paid Qualified Leave Wages to its employees in the calendar quarter prior to the time of the required deposit, (2) The amount of Employment Taxes that the employer does not timely deposit is less than or equal to the amount of the employer’s anticipated credits under sec tions 7001 and 7003 of the Families First Act for the calendar quarter as of the time of the required deposit, and (3) The employer did not seek payment of an advance credit by filing Form 7200, Advance Payment of Employer Credits Due to COVID19, with respect to the an ticipated credits it relied upon to reduce its deposits. Thus, an employer may reduce, with out a penalty under section 6656 of the Code, the amount of a deposit of Employ ment Taxes by the amount of Qualified Leave Wages and Qualified Health Plan Expenses paid by the employer in the cal endar quarter prior to the required deposit, plus the amount of the employer’s share of Medicare tax on such Qualified Leave Wages, as long as the employer does not also seek an advance credit with regard to the same amount. For purposes of this section 3.a of this notice, the total amount of any reduction in any required deposit may not exceed the total amount of Qualified Leave Wag es and Qualified Health Plan Expenses and the employer’s share of Medicare tax on the Qualified Leave Wages in the cal endar quarter, minus any amount of Qual ified Leave Wages, Qualified Health Plan Expenses, and employer’s share of Medi care tax that had been previously used (1) to reduce a prior required deposit in the calendar quarter and obtain the relief pro vided by this notice or (2) to seek payment of an advance credit. b. Employment Taxes Related to Quali- fied Retention Wages An eligible employer will not be sub ject to a penalty under section 6656 for failing to deposit Employment Taxes re lating to Qualified Retention Wages in a calendar quarter if— (1) The employer paid Qualified Re tention Wages to its employees in the calendar quarter prior to the time of the required deposit, (2) The amount of Employment Taxes that the employer does not timely depos it, reduced by the amount of Employment Taxes not deposited in anticipation of the credits claimed for Qualified Leave Wag es, Qualified Health Plan Expenses, and the employer’s share of Medicare tax on the Qualified Leave Wages under sections 7001 and 7003 (as described in section 3.a of this notice), is less than or equal to the amount of the employer’s anticipated credits under section 2301 of the CARES Act for the calendar quarter as of the time of the required deposit, and (3) The employer did not seek payment of an advance credit by filing Form 7200, Advance Payment of Employer Credits Due to COVID19, with respect to the an ticipated credits it relied upon to reduce its deposits. Thus, after a reduction, if any, of a de posit of Employment Taxes by the amount of credits anticipated for Qualified Leave Wages under sections 7001 and 7003 (as described in section 3.a of this notice), an employer may further reduce, without a penalty under section 6656 of the Code, the amount of the deposit of Employment Taxes by the amount of Qualified Reten tion Wages paid by the employer in the calendar quarter prior to the required de posit, as long as the employer does not April 20, 2020 666 Bulletin No. 2020–17 also seek an advance credit with regard to the same amount. For purposes of this section 3.b of this notice, the total amount of any reduction in any required deposit may not exceed the total amount of Qualified Retention Wages in the calendar quarter, minus any amount of Qualified Retention Wages that had been previously used (1) to reduce a prior required deposit in the calendar quarter and obtain the relief provided by this notice or (2) to seek payment of an advance credit. SECTION 4. CONTACT INFORMATION The principal author of this notice is Michael A. Franklin of the Office of the Associate Chief Counsel (Procedure and Administration). For further information, please contact Mr. Franklin at (202)317 5436 (not a tollfree number). Bulletin No. 2020–17 667 April 20, 2020 Part IV Announcement Regarding Procedures Related to Regulations Announcement 2020-4 The Department of the Treasury and the Internal Revenue Service (IRS) an nounce that public hearings conducted by the IRS on notices of proposed rulemak ing related to the internal revenue laws will be held telephonically until further notice, and encourage taxpayers to submit public comments electronically. Conducting Public Hearings Telephonically Until further notice, all public hearings on notices of proposed rulemaking will be conducted by telephone. Individuals who want to testify at a public hearing still must request to testify, submit timely public com ments, and submit outlines of topics they intend to cover in their testimony. Deadlines for timely submission can be found in no tices of proposed rulemaking. Speakers still will have up to ten minutes to testify and may be asked questions by the panel. Additionally, individuals who want to testify (by telephone) at a public hearing must send an email to publichearings@irs. gov to receive the telephone number and ac cess code for the hearing. The subject line of the email must contain the regulation num ber (REGXXXXXXXX) for the hearing and the word TESTIFY. For example, the subject line may say: Request to TESTIFY at Hearing for REG12345600. The email should also include a copy of the speaker’s public comments and outline of topics. The email must be received by the deadline, as identified in the notice of proposed rulemak ing, to submit an outline of topics. Individuals who want to attend (by tele phone) a public hearing must also send an email to publichearings@irs.gov to receive the telephone number and access code for the hearing. The subject line of the email must contain the regulation number (REG XXXXXXXX) and the word ATTEND. For example, the subject line may say: Request to ATTEND Hearing for REG 12345600. The email requesting to attend the public hearing must be received by 5:00 P.M. two (2) business days before the date that the hearing is scheduled. Any questions regarding speaking at or attending a public hearing may also be emailed to publichearings@irs.gov. The telephonic hearings will be made accessible to people with disabilities. To request special assistance during the tele phonic hearing please contact the Publica tions and Regulations Branch of the Office of Associate Chief Counsel (Procedure and Administration) by sending an email to publichearings@irs.gov (preferred) or by telephone at (202) 3175177 (not a tollfree number) at least three (3) days prior to the date that the telephonic hearing is scheduled. Submission of Public Comments through Regulations.gov Commenters are strongly encouraged to submit public comments via the Federal eRulemaking Portal at www.regulations. gov. The IRS expects to have limited per sonnel available to process public com ments that are submitted on paper through mail. Until further notice, any comments submitted on paper will be considered to the extent practicable. CONTACT INFORMATION The principal author of this notice is Em ily M. Lesniak of the Office of the Associate Chief Counsel (Procedure and Administra tion). For further information regarding this notice, contact Emily M. Lesniak at (202) 3173400 (not a tollfree number). Notice of Proposed Rulemaking Computation and Reporting of Reserves for Life Insurance Companies REG-132529-17 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations that provide guid ance on the computation of life insur ance reserves and the change in basis of computing certain reserves of insurance companies. These proposed regulations implement recent legislative changes to the Internal Revenue Code. This docu ment invites comments on these proposed regulations. This document affects entities taxable as insurance companies. DATES: Written or electronic comments and requests for a public hearing must be received by June 1, 2020. ADDRESSES: Submit electronic submis sions via the Federal eRulemaking Portal at www.regulations.gov (indicate IRS and REG13252917) by following the online instructions for submitting comments. Once submitted to the Federal eRulemak ing Portal, comments cannot be edited or withdrawn. The Department of the Trea sury (Treasury Department) and the IRS will publish for public availability any comment received to its public docket, whether submitted electronically or in hard copy. Send hard copy submissions to: CC:PA:LPD:PR (REG13252917), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. FOR FURTHER INFORMATION CON TACT: Concerning the proposed regu lations, Dan Phillips, (202) 3176995; concerning submissions of comments and requests for a public hearing, Regina Johnson, (202) 3175177 or fdms.data base@irscounsel.treas.gov (not tollfree numbers). SUPPLEMENTARY INFORMATION: Background This document contains proposed amendments to 26 CFR part 1 under sec tions 807 and 816 of the Internal Revenue Code (Code). Sections 807 and 816 were added to the Code by section 211(a) of the Deficit Reduction Act of 1984, Public April 20, 2020 668 Bulletin No. 2020–17 Law 98369, 98 Stat. 494. Section 807 was amended by sections 13513 and 13517 of the Tax Cuts and Jobs Act, Public Law 11597, 131 Stat. 2054, 2143, 2144 (2017) (TCJA). These amendments by the TCJA apply to taxable years beginning after De cember 31, 2017. This document also proposes to amend or remove the following regulations in 26 CFR: §§1.33811, 1.381(c)(22)1, 1.8012, 1.8015, 1.8017, 1.8018, 1.806 4, 1.8071, 1.8092, 1.8095, 1.8103, 1.817A0, 1.817A1, 1.8182, 1.8184, 1.8481, 1.60122, and 301.91006T. These proposed changes are conforming changes to regulations that (i) relate to re pealed or amended law, (ii) reference reg ulations that are proposed to be removed, (iii) have no future application, or (iv) re late to other regulations proposed by this document. A. Reserves Taken into Account in Determining Life Insurance Company Taxable Income Section 801(a) imposes a tax on the life insurance company taxable income of every life insurance company. Section 801(b) defines life insurance company taxable income to mean life insurance gross income, reduced by life insurance deductions. Under section 803(a)(2), life insurance gross income includes a net de crease in items described in section 807(c) as required by section 807(a). Under sec tions 804 and 805(a)(2), life insurance deductions include a deduction for a net increase in items as required by section 807(b). The items described in section 807(c) are: (i) life insurance reserves (as defined in section 816(b)); (ii) unearned premi ums and unpaid losses included in total reserves; (iii) amounts that are discounted at the appropriate rate of interest to satisfy obligations under insurance and annuity contracts that do not involve life, accident, or health contingencies when the compu tation is made; (iv) dividend accumula tions and other amounts held at interest in connection with insurance and annuity contracts; (v) premiums received in ad vance and liabilities for premium deposit funds; and (vi) reasonable special contin gency reserves under contracts of group term life insurance or group accident and health insurance that are held for retired lives, premium stabilization, or a combi nation of both. B. Life Insurance Reserves Taken into Account in Determining Premiums Earned for a Nonlife Insurance Company Section 831(a) generally imposes a tax on the taxable income of every insur ance company other than a life insurance company (a nonlife insurance company). Section 832 defines taxable income for this purpose to be gross income (as de fined in section 832(b)(1)) less allowed deductions. Section 832(b)(1) provides that gross income includes underwriting income, and section 832(b)(3) provides that underwriting income means premi ums earned on insurance contracts during the taxable year less losses incurred and expenses incurred. Under sections 832(b)(4) and 832(b) (7)(A), premiums earned on insurance contracts during the taxable year are re duced by life insurance reserves at the end of the taxable year and increased by life insurance reserves at the end of the preceding taxable year. For this pur pose, life insurance reserves are defined in section 816(b) but determined under section 807(d). C. Method of Computing Life Insurance Reserves for Purposes of Determining Income 1. Prior to modification by the TCJA Section 807(d) sets forth rules for com puting the amount of life insurance reserves for a contract for purposes of determining life insurance company taxable income and for purposes of computing premiums earned for a nonlife insurance company. Prior to amendment by the TCJA, section 807(d)(1) provided that the amount of the life insurance reserves for any contract was the greater of the net surrender value of the contract (determined under section 807(e) (1)) or the federally prescribed reserve determined under section 807(d)(2). This amount, however, could not exceed the amount that would have been taken into account with respect to the contract in de termining statutory reserves (as defined in prior section 807(d)(6)). Prior section 807(d)(2) provided that the federally prescribed reserve for a con tract was computed using (i) the tax re serve method applicable to the contract, (ii) the greater of the applicable Federal interest rate or the prevailing state as sumed interest rate, and (iii) the prevailing commissioners’ standard tables for mor tality and morbidity, adjusted as appro priate to reflect the risks (such as substan dard risks) incurred under the contract that were not otherwise taken into account. In the case of a contract to which the Commissioners’ Reserve Valuation Meth od (CRVM) applied (generally, a life in surance contract), prior sections 807(d) (3)(A)(i) and 807(d)(3)(B)(i) provided that the tax reserve method applicable to the contract was the CRVM as prescribed by the National Association of Insurance Commissioners (NAIC) that was in effect on the date the contract was issued. Sim ilarly, in the case of a contract to which the Commissioners’ Annuity Reserve Val uation Method (CARVM) applied (gener ally, an annuity contract), prior sections 807(d)(3)(A)(ii) and 807(d)(3)(B)(ii) pro vided that the tax reserve method appli cable to the contract was the CARVM as prescribed by the NAIC that was in effect on the date the contract was issued. Other parameters, such as the appropriate inter est rate and mortality tables, were likewise generally determined with reference to the date the contract was issued. Section 1.8071 provided instructions on what mortality and morbidity tables taxpayers should have used to compute life insurance reserves for a contract for which there were no applicable commis sioners’ standard tables when the contract was issued. Section 1.8071 was pub lished as a final regulation in the Federal Register (54 FR 52933) on December 26, 1989 (T.D. 8278). 2. Principle-based reserves and IRS notices In recent years, the NAIC has pro mulgated and states have adopted prin ciplebased reserving methods to better reflect the economics of more complex life insurance and annuity products. Prin ciplebased reserves (PBR) are intended to replace a more formulaic approach to determining policy reserves with an ap Bulletin No. 2020–17 669 April 20, 2020 proach that takes into account a range of future economic conditions and more closely reflects the risks of complex insur ance products. See, e.g., Principle-Based Reserves for Life Products under the NAIC Valuation Manual, Actuarial Stan dard of Practice No. 52, Actuarial Stan dards Board, Sept. 2017, App 1. Federal income tax issues arose when trying to apply the requirements of prior section 807(d) to tax reserve methods that were PBR methods. It was not clear how aspects of PBR methods fit within the stat utory requirements of prior section 807(d). For example, a PBR method may require reserves to be computed based on many different scenarios in which many differ ent interest rate assumptions are made, but prior section 807(d) required the use of a single interest rate when computing the reserve for a contract. In 2008, the IRS issued Notice 200818, 20081 C.B. 363, to alert life insurance com panies that Federal tax issues might arise as a result of the thenproposed PBR methods, identify areas of concern, and invite com ments on these and other issues. Several comments were received and considered. In 2010, the IRS issued Notice 2010 29, 201015 I.R.B. 547, to provide inter im guidance to issuers of variable annuity contracts as a result of the adoption by the NAIC of Actuarial Guideline 43 (AG 43), which describes a PBR method. The interim guidance provided, among other things, that (i) for purposes of determining whether an insurance company satisfies the 50 percent of reserves test for quali fication as a life insurance company un der section 816(a), the Standard Scenario Amount (SSA) determined under AG 43 is included in life insurance reserves as defined in section 816(b) and total re serves as defined in section 816(c), (ii) for purposes of applying the statutory reserve cap of section 807(d)(1), the term “statu tory reserves” under prior section 807(d) (6) (current section 807(d)(4)) includes the SSA, provided the requirements of prior section 807(d)(6) are otherwise met, and (iii) for purposes of determining the amount of the reserve under prior section 807(d)(2) for contracts falling within the scope of AG 43 and issued on or after De cember 31, 2009, the provisions for deter mining the SSA are taken into account and the provisions for determining the condi tional tail expectation amount (a compo nent of AG 43) are not taken into account. 3. Modification by the TCJA Section 13517 of the TCJA amend ed section 807(d)(1) to provide general ly that, for purposes of determining life insurance company taxable income, the amount of the life insurance reserves for any contract (other than a contract to which section 807(d)(1)(B) applies (relat ing to variable contracts)), is the greater of the net surrender value of such contract or 92.81 percent of the reserve determined under section 807(d)(2). The amount of the life insurance reserve for a variable contract, as specified in amended section 807(d)(1)(B), is the sum of (i) the greater of the net surrender value of such contract or the portion of the reserve that is sepa rately accounted for under section 817 and (ii) 92.81 percent of the excess (if any) of the reserve determined under section 807(d)(2) over the amount in clause (i). Section 13517 of the TCJA amended prior section 807(d)(2) to provide that the amount of the reserve under section 807(d)(2) is determined using the tax re serve method applicable to such contract. Section 13517 of the TCJA also amended prior section 807(d)(3) to provide general ly that the tax reserve method applicable to a contract is the method prescribed by the NAIC that applies to the contract as of the date the reserve is determined, not the date the contract was issued, as was required prior to the TCJA. The TCJA did not change the treatment of asset adequacy reserves. Asset adequa cy reserves and similar reserves that ad dress solvency concerns of state regulators but do not meet technical actuarial re quirements have long been excluded from life insurance reserves for Federal income tax purposes. See, e.g., Rev. Rul. 67435, 19672C.B. 232; Old Line Insurance Co. v. Commissioner, 13 B.T.A. 758 (1928). The Conference Report to the TCJA states that “[a]s under present law, no deduction for asset adequacy reserves or deficiency reserves is allowed.” H.R. Rep. No. 115 466, at 477 (2017) (Conference Report). See also Staff of the Joint Committee on Taxation, 115th Cong., General Explana tion of Public Law 11597, 235 (Comm. Print 2018) (Bluebook). Section 13517(c)(3) of the TCJA pro vided a transition rule that requires any difference between (i) the amount of life insurance reserves with respect to any contract as of the close of the taxable year preceding the first taxable year beginning after December 31, 2017, computed using the method prescribed by the TCJA and (ii) the amount of such reserves computed using the method prior to the amendments by the TCJA, to be taken into account over the eight succeeding taxable years. Rev. Proc. 201934, 201935 I.R.B. 669, provides simplified procedures for an in surance company to obtain consent of the Commissioner of Internal Revenue or his delegate (Commissioner) to change its method of accounting for life insurance reserves to comply with the amendments to section 807 made by the TCJA. D. Change in Basis of Computing Reserves 1. Prior to modification by the TCJA a. Statutory provisions Prior to amendment by the TCJA, sec tion 807(f)(1) provided that if the basis for determining any item described in sec tion 807(c) (for example, life insurance reserves) as of the close of any taxable year differed from the basis for that deter mination as of the close of the preceding taxable year, then so much of the differ ence between the amount of the items at the close of the taxable year computed on the new basis and the amount of the item at the close of the taxable year computed on the old basis, as is attributable to con tracts issued before the taxable year, was taken into account ratably for each of the succeeding ten taxable years. Prior section 807(f) was substantial ly similar to and replaced prior section 810(d) as enacted by the Life Insurance Company Income Tax Act of 1959, Public Law 8669, 73 Stat. 112 (1959). By en acting prior section 810(d), Congress pro vided a specific treatment for adjustments resulting from a change in method of com puting reserves that otherwise would have been subject to the general tax rules un der section 481 for changes in method of accounting. See, e.g., American General Life and Accident Insurance Co. v. United April 20, 2020 670 Bulletin No. 2020–17 States, 901 USTC (CCH) ¶ 50,010 (M.D. Tenn.1989) (section 481 is a more general provision dealing with a broad variety of cases and section 810, on the other hand, is much more specific and deals with a very narrow and limited type of change in method of accounting). If a company ceases to qualify as a life insurance company, section 807(f)(2), which was not amended by the TCJA, requires, except as provided in section 381(c)(22), that the balance of any ad justment under section 807(f) be taken into account in the taxable year preced ing the taxable year in which the taxpay er no longer qualifies as a life insurance company. b. Regulatory provisions Regulations relating to the change in method of computing reserves were ad opted under Code provisions that existed prior to their repeal by the Deficit Reduc tion Act of 1984. If and to the extent the Deficit Reduction Act of 1984 incorpo rated provisions of prior law, regulations and other guidance generally continued to serve as interpretive guides to the new provisions. H.R. Rep. No. 98432, pt. 2, at 1401 (1984). Section 1.8015(c) provides that if reserves are claimed by a life insurance company then sufficient information must be filed with the return to enable the val idation of the claim. Section 1.8015(c) also requires certain information to be filed if the basis (for Federal income tax purposes) for determining the amount of the life insurance reserves as of the close of the taxable year differs from the basis for such determination as of the beginning of the taxable year. Section 1.8015 was published as a final regulation in the Fed- eral Register (25 FR 12654) on Decem ber 10, 1960 (T.D. 6513). Section 1.8064 describes prior sec tion 806(b) and provides that a change in basis of computing any of the items in prior section 810(c) (the predecessor to section 807(c)) is not a change in method of accounting requiring the consent of the Secretary of the Treasury or his delegate (Secretary) under section 446(e). Section 1.8064 was published as a final regulation in the Federal Register (25 FR 12654) on December 10, 1960 (T.D. 6513). Section 1.8103 describes how a change in basis of computing the items in prior section 810(c) should have been treated under the Code prior to its amend ment by the Deficit Reduction Act of 1984. Section 1.8103(a) provides that if the basis for determining an item in pri or section 810(c) at the end of a taxable year differs from the basis for such deter mination at the end of the preceding tax able year, then the difference between the amount of the item computed at the end of the taxable year on the new basis and the amount of the item computed at the end of the taxable year on the old basis is generally taken into account ratably over the 10 succeeding taxable years. Example 1 of §1.8103(b) illustrates that if there is a change in basis of computing an item described in former section 810(c) during a taxable year, then for purposes of deter mining any increase or decrease in such item during the taxable year, such increase or decrease is the difference between the amount of such item computed at the be ginning of the taxable year on the old ba sis and the amount of such item computed at the end of the taxable year on the old basis. Section 1.8103(c) further provides that, subject to section 381(c)(22), if a company ceases to qualify as a life insur ance company, the balance of any adjust ment resulting from the change in method of computing reserves must be taken into account in the taxable year preceding the taxable year in which the taxpayer no lon ger qualifies as a life insurance company. Section 1.8103 was published as a final regulation in the Federal Register (25 FR 12654) on December 10, 1960 (T.D. 6513). Section 1.8182(c) describes prior sec tions 806(b) and 810(d)(1). Section 1.818 2 was published as a final regulation in the Federal Register (26 FR 2781) on April 4, 1961 (T.D. 6558). c. IRS guidance The application of section 807(f) prior to its amendment by the TCJA and the ap plication of prior section 810(d) are illus trated by Rev. Rul. 20026, 20021 C.B. 460 (inclusion of factors omitted in a pre vious year’s determination of reserves is a change in basis under prior section 807(f) and taxpayer may correct the method on an amended return); Rev. Rul. 9474, 19942 C.B. 157 (applying prior section 807(f) in several situations in which taxpayer changed the basis of computing life insur ance reserves); Rev. Rul. 80117, 19801 C.B. 143 (revocation of the election to re compute life insurance reserves under pri or section 818(c) of a company acquired in a merger results in a recomputation of the reserves, which is a change in basis of computing the reserves subject to the 10 year spread of prior section 810(d)); Rev. Rul. 80116, 19801 C.B. 141 (recomputa tion of life insurance reserves under prior section 818(c) of a company acquired in a merger is not a change in basis of com puting reserves under prior section 810(d) because reserves must be recomputed for both beginning and end of year); Rev. Rul. 78354, 19782 C.B. 190 (election of a life insurance company to recompute life insurance reserves under prior section 818(c) is terminated when company fails to qualify as a life insurance company and the required recomputation of the re serves is a change in basis of computing the reserves subject to the 10 year spread of prior section 810(d); method of nonlife insurance company taking 10 year spread into account is shown); Rev. Rul. 77198, 19771 C.B. 190 (recomputation of cer tain reserves from a nonactuarial method to a method utilizing recognized mortality tables and assumed rates of interest is a change in basis of computing reserves un der prior sections 806(b) and 810(d)); Rev. Rul. 75308, 19752 C.B. 264 (change in basis of computing reserves under prior section 810(d) occurs when the addition to the reserve is made, not when the com pany adopts the policy to change the basis of computing reserves); Rev. Rul. 7457, 19741 C.B. 163 (life insurance company that changes basis of computing reserves must take into account the entire adjust ment under prior section 810(d) in the year of change if it ceases to qualify as a life in surance company in the year after the year of change); Rev. Rul. 70568, 19702 C.B. 140 (recomputation of reserves under prior section 818(c) applies to contracts at beginning of year even if they are not held at end of year; prior section 810(d) does not apply to the recomputation); Rev. Rul. 70192, 19701 C.B. 153 (change in assumption of when in year death bene fits would be paid is a change in basis of Bulletin No. 2020–17 671 April 20, 2020 computing reserves under prior sections 806(b) and 810 (d)); Rev. Rul. 69444, 19692 C.B. 145 (an increase in life in surance reserves attributable solely to the addition of a new benefit on existing con tracts is not a change in basis of comput ing reserves under prior sections 806(b) and 810(d)); Rev. Rul. 65240, 19652 C.B. 236 (a nonlife company’s change in basis of computing life insurance reserves is a change in basis of computing reserves under prior section 810(d) and is subject to the 10 year spread); Rev. Rul. 65233, 19652 C.B. 228 (prior sections 806(b) and 810(d) apply in the year of a change in basis of computing reserves notwith standing that state regulatory approval for change was not received until the follow ing year); and Rev. Rul. 65143, 19651 C.B. 261 (change in method of computing life insurance reserves from a preliminary term basis to a net level premium basis is a change in basis of computing reserves under prior sections 806(b) and 810(d); election under prior section 818(c) does not apply to life insurance contracts that are computed for statutory purposes on a net level premium basis at the end of the year of election). d. Nonlife insurance companies Section 832(b)(4) requires a nonlife insurance company to include life insur ance reserves, as defined in section 816(b) and determined under section 807, in its determination of premiums earned on in surance contracts during the taxable year, which is a component of underwriting income. Section 807(f) provides rules for changing the basis for determining any item referred to in section 807(c), and life insurance reserves are referred to in section 807(c)(1). Nonlife insurance com panies are required to follow the require ments in section 807(f) to change the basis of computing life insurance reserves. Rev. Rul. 65240. 2. Modification by the TCJA Section 13513 of the TCJA amended prior section 807(f) to provide that any difference between the amount of an item referred to in section 807(c) as of the close of the taxable year computed on a new ba sis and the amount of such item as of the close of the taxable year computed on the old basis, as is attributable to contracts is sued before the taxable year, is to be taken into account under section 481 as adjust ments attributable to a change in method of accounting initiated by the taxpayer and made with the consent of the Secretary. Section 811(a), which was not amend ed by the TCJA, generally provides that computations made for the determination of Federal income taxes imposed by the provisions of subchapter L of chapter 1 of the Code (subchapter L) that are set forth in part I shall be made under an ac crual method of accounting or, to the ex tent permitted under regulations, under a combination of an accrual method and any other permitted method. To the extent not inconsistent with the preceding sen tence or any other provision in part I of subchapter L, these computations are to be made in a manner consistent with the manner required for the annual statement approved by the NAIC. Section 811(a) does not affect the application of section 446(e), which generally requires a taxpay er to secure the consent of the Secretary before changing the method of computing the taxpayer’s taxable income. See also §1.4461(e). After the amendment of section 807(f) by the TCJA, a life insurance company must follow the regular administrative procedures for a change in method of ac counting for a change in basis of comput ing reserves referred to in section 807(c). See, e.g., §1.4461(e); Rev. Proc. 201513, 20155 I.R.B. 419, Rev. Proc. 201943, 201948 I.R.B. 1107; Rev. Proc. 2002 18, 20021 C.B. 678. Similarly, a nonlife insurance company must follow the ad ministrative procedures for a change in method of accounting to change its basis of computing life insurance reserves (as defined in section 816(b)). The Conference Report explained that under the amended law “[i]ncome or loss [sic] resulting from a change in method of computing life insurance company re serves is taken into account consistent with IRS procedures, generally ratably over a fouryear period, instead of over a 10year period.” Conference Report at 467. The Joint Committee on Taxation explained that a company that makes a change in method of computing life in surance company reserves is required to report and file such statements and oth er information as the Secretary requires under the IRS procedures for accounting method changes, including the procedures for obtaining automatic consent to change an accounting method. Bluebook at 228. Rev. Proc. 201513 provides the IRS procedures for a taxpayer to obtain the advance (nonautomatic) or automatic consent of the Commissioner to change a method of accounting. These proce dures generally require a taxpayer to file a Form 3115, “Application for Change in Accounting Method,” to change the tax payer’s method of accounting. Rev. Proc. 201910, 201902 I.R.B. 296, modified the list of automatic accounting method changes in Rev. Proc. 201831, 201822 I.R.B. 637, to add section 26.04, which provided procedures for an insurance company to obtain automatic consent of the Commissioner to change its method of accounting to comply with section 807(f) for taxable years beginning after Decem ber 31, 2017. In response to comments, section 26.04 of Rev. Proc. 201831 was modified and superseded by Rev. Proc. 201943. See section 26.04 of Rev. Proc. 201943 for the current procedures for an insurance company to obtain automatic consent of the Commissioner to change its method of accounting to comply with section 807(f). Rev. Proc. 201910 also modified Rev. Rul. 9474 and Rev. Rul. 20026 to the extent their holdings are inconsistent with the general rules for changing a method of accounting under section 446(e) and §1.4461(e). Rev. Proc. 200218 provides the IRS procedures for changes in method of accounting imposed by the IRS and other procedures for re solving accounting method issues. E. Reporting of Reserves Section 13517 of the TCJA added sec tion 807(e)(6), which provides that the Secretary shall require reporting (at such time and in such manner as the Secretary shall prescribe) with respect to the open ing and closing balance of reserves and with respect to the method of computing reserves for purposes of determining in come. The Conference Report states that for this purpose the Secretary may require a life insurance company (including an af April 20, 2020 672 Bulletin No. 2020–17 filiated group filing a consolidated return that includes a life insurance company) to report each of the line item elements of each separate account by combining them with such items from other separate accounts and the general account and re port the combined amounts on a lineby line basis. The Secretary may also provide that the reporting on a separate account by separate account basis is generally not permitted. The Conference Report further states that under existing regula tory authority, the Secretary may require efiling or comparable filing of the returns and may require that the taxpayer provide its annual statement via a link, electronic copy, or other similar means. Conference Report at 47879. F. Annual Statements and Electronically Filed Forms 1120-L and 1120-PC Section 6012(a)(2) generally requires that returns with respect to income taxes must be made by every corporation sub ject to taxation under subtitle A of the Code. Final regulations under section 6012 related to insurance companies were published in the Federal Register (72 FR 32794) on June 14, 2007 (T.D. 9329). Section 1.60122(c)(1) provides that a life insurance company must make a return on Form 1120L, “U.S. Life Insurance Company Income Tax Return,” and, ex cept as provided in §1.60122(c)(4), file with its return a copy of its annual state ment. Similarly, §1.60122(c)(2) requires every domestic insurance company other than a life insurance company to make a return on Form 1120PC, “U.S. Property and Casualty Insurance Company Income Tax Return,” and, except as provided in §1.60122(c)(4), file with its return a copy of its annual statement. For these purpos es, an annual statement means the annual statement, the form of which is approved by the NAIC, that is filed by an insurance company for the year with the applicable state regulators or, if the insurance compa ny is not required to file the NAIC annual statement, a pro forma annual statement. Section 1.60122(c)(3) generally provides that the requirements of §1.60122(c)(1) and (2) concerning returns and annual statements also apply to foreign insurance companies subject to tax under section 801 or section 831. Section 1.60122(c)(4) provides that if an insurance company described in §1.60122(c)(1), (2), or (3) files its re turn electronically, it should not include its annual statement with such return but that such statement (or pro forma annual statement) must be available at all times to the IRS. Explanation of Provisions A. Computation of Life Insurance Reserves Section 1.8071(a) of the proposed regulations provides that no asset adequa cy reserve may be included in the deter mination of the amount of life insurance reserves under section 807(d). This pro posed regulation is consistent with the law both before and after the TCJA. The sub stantive rules in current §1.8071 have no application for taxable years beginning af ter December 31, 2017, and therefore, are not included in §1.8071 of the proposed regulations. B. Reporting of Reserves Section 1.8073 of the proposed regu lations allows the IRS to require informa tion necessary for the proper reporting of items described in section 807(c), includ ing separate account items. This provision is consistent with section 807(e)(6), as added by the TCJA. C. Change in Basis of Computing Reserves 1. Proposed Section 1.807-4 Section 1.8074 of the proposed reg ulations provides guidance relating to both the change in basis of computing reserves of a life insurance company and the change in basis of computing life in surance reserves of a nonlife insurance company. Section 1.8074(a) of the pro posed regulations requires an insurance company to follow administrative proce dures prescribed by the Commissioner to change the basis of computing reserves. This requirement is consistent with the Conference Report relating to section 13513 of the TCJA, which provides that a taxpayer is required to follow IRS proce dures. Conference Report at 467; see also Bluebook at 228 (a company is required to comply with procedures for automat ic method changes and to report and file statements and other information as the Secretary requires). Section 1.8074(b) of the proposed reg ulations provides that, to avoid the double counting of income or a deduction, a tax payer that changes its basis of computing reserves is required to take into account under section 481(a) an adjustment at tributable to the change in basis. The pro posed regulations provide that if a taxpay er loses its insurance company status, then any remaining balance of a section 481(a) adjustment must be taken into account in the last taxable year the taxpayer was an insurance company. This proposed rule, however, would not require an insurance company to accelerate the accounting for such adjustment if it changes from a life insurance company to a nonlife insurance company or vice versa. Section 1.8074(c) of the proposed regulations provides that for purposes of determining any increase or decrease in items described in section 807(c) (for a life insurance company) or the amount of life insurance reserves (for a nonlife insurance company), the determination should be made for the year of change using the old basis of computing reserves and should be made in the following tax able year using the new basis of comput ing reserves. Certain revenue rulings are inconsis tent with section 807(f), as amended by the TCJA. Accordingly, these revenue rul ings are proposed to be obsoleted for tax able years beginning on or after the date of publication of the Treasury decision adopting these rules as final regulations in the Federal Register. See Effect on Other Documents. 2. Procedure for Obtaining Automatic Consent Section 26.04 of Rev. Proc. 201943 provides the current procedures for an insurance company to obtain automatic consent of the Commissioner to change its method of accounting to comply with section 807(f). In response to comments, the Treasury Department and the IRS in tend to revise section 26.04 of Rev. Proc. Bulletin No. 2020–17 673 April 20, 2020 201943 as described in the following paragraphs. First, section 26.04(2)(b)(ii) of Rev. Proc. 201943 provides that multiple changes during the same taxable year for the same type of contract are considered a single change in basis and the effects of such changes are netted and treated as a single section 481(a) adjustment. Section 807(f)(1), however, provides that the sec tion 481(a) adjustment is the difference between the amount of any item referred to in section 807(c) computed on the new basis and the amount of such item computed on the old basis. Accordingly, the Treasury Department and the IRS in tend to revise section 26.04 of Rev. Proc. 201943 to require netting of the section 481(a) adjustments at the level of each item referred to in section 807(c) so there is a single section 481(a) adjustment for each of the items referred to in section 807(c). Second, section 26.04(1) of Rev. Proc. 201943 provides that the automatic change procedures apply to a nonlife in surance company. The Treasury Depart ment and the IRS intend to revise section 26.04 of Rev. Proc. 201943 to clarify the manner in which nonlife insurance com panies implement changes to the basis of computing life insurance reserves (as de fined in section 816(b)) during a taxable year (year of change). Specifically, the clarification would provide that, if a non life insurance company changes the basis of computing its life insurance reserves, then for purposes of applying section 832(b)(4), (i) for the year of change, life insurance reserves at the end of the year of change with respect to contracts issued before the year of change are determined on the old basis and (ii) for the year fol lowing the year of change, life insurance reserves at the end of the preceding tax able year with respect to contracts issued before the year of change are determined on the new basis. Life insurance reserves attributable to contracts issued during the year of change and thereafter must be computed on the new basis. D. Definition of Life Insurance Reserves The TCJA modified section 807(d) to provide that, for purposes of part I of subchapter L (other than section 816), the amount of life insurance reserves for any contract (other than a variable contract) is the greater of the net surrender value of such contract or 92.81 percent of the reserve determined under the applica ble tax reserve method. For any variable contract, the amount of the life insurance reserve is the sum of (i) the greater of the net surrender value of such contract or the portion of the reserve that is separate ly accounted for under section 817 and (ii) 92.81 percent of the excess (if any) of the reserve determined under the applica ble tax reserve method over the amount in clause (i). Section 807(d)(3) provides that the ap plicable tax reserve method is CRVM in the case of a contract covered by CRVM and CARVM in the case of a contract covered by CARVM. The CRVM and CARVM may be PBR methods, which may be gross premium reserves and may take into account certain expenses and other factors. Congress understood that for this purpose life insurance reserves could be determined using PBR methods. The Joint Committee on Taxation described the purpose of the TCJA’s amendments to section 807(d) as “accomodat[ing] the NAICprescribed principlebased reserve methodology.” Bluebook at 235. Section 807(c)(1), however, provides that the reserves referred to in sections 807(a) and (b), which are the reserves tak en into account in determining the gross income or deductions of a life insurance company, are “life insurance reserves (as defined in section 816(b)).” Section 816(b) generally defines life insurance reserves to be amounts that are (i) computed or estimated on the basis of recognized mortality or morbidity tables and assumed rates of interest, (ii) set aside to mature or liquidate, either by payment or reinsurance, future unaccrued claims arising from life insurance, annuity, and noncancellable accident and health insur ance contracts involving, at the time with respect to which the reserves are comput ed, life, accident, or health contingencies, and (iii) with some exceptions, required by law. Section 816(b) (and its prede cessor provisions) have been interpreted as describing a net premium reserve that does not take into account expenses or certain other factors. See, e.g., Rev. Rul. 77451, 19772 C.B. 224; Maryland Ca- sualty Co. v. United States, 251 U.S. 342 (1920). Thus, although Congress intended that the tax reserve method used to com pute life insurance reserves under section 807(d), as amended by the TCJA, could include PBR methods, section 816(b) (by virtue of the reference in section 807(c) (1)) could be interpreted to preclude re serves determined under PBR methods from qualifying as life insurance reserves for purposes of section 807. To clarify the interaction between sections 807 and 816, §1.8161 of the proposed regulations provides that a reserve that meets the re quirements in sections 816(b)(1) and (2) will not be disqualified as a life insurance reserve if it is determined using a meth od that takes into account other factors, provided that the method used to compute the reserves is a “tax reserve method” as defined in section 807(d)(3). This defini tion would apply to life insurance reserves taken into account by nonlife insurance companies under section 832(b)(4) and for purposes of determining an insurance company’s qualification as a life insurance company under section 816. E. Electronic Filing of Annual Statements The Conference Report contemplates requiring the electronic filing of annual statements to improve reporting of in surance reserves, as necessary to carry out and enforce section 807. Conference Report at 47879. The Treasury Depart ment and the IRS believe that requiring an insurance company to file its annual statement electronically (if the company’s Form 1120L or Form 1120PC is also filed electronically) is necessary to allow the IRS to better and more efficiently exam ine the return. Accordingly, §1.60122(c) is proposed to be amended to remove the rule that prohibits an insurance company that files its Form 1120L or Form 1120 PC electronically from filing its annual statement (or pro forma annual statement) electronically. The Treasury Department and the IRS request comments regarding potential issues that may arise in filing the annual statement (or pro forma annual statements) electronically (for example, if the size of the annual statement(s) may exceed or cause the filed return to exceed the size limits in section 2.1.2 (Submis April 20, 2020 674 Bulletin No. 2020–17 sion Size) of IRS Publication 4164, Mod- ernized e-File (MeF) Guide for Software Developers and Transmitters, Processing Year 2020.) F. Proposed Removal or Revision of Regulations with No Future Application. 1. In general This notice of proposed rulemaking proposes to remove §§1.8017, 1.8018(e), 1.8064, 1.8092, 1.8103, 1.8182(c), and 1.8184 because these provisions provide guidance under law that has been repealed or substantially changed and will have no application after the adoption of the pro posed regulations as final. Section 1.801 5(c) is proposed to be removed because its requirement that a taxpayer file certain information when it changes the basis of computing life insurance reserve is obvi ated by the requirement in §1.8074(b) of the proposed regulations that a taxpayer changing the basis of computing any item referred to in section 807(c) follow the ad ministrative procedures prescribed by the Commissioner. This notice of proposed rulemaking proposes to revise §301.91006T to re move provisions related to elections under law that has been repealed or elections that may no longer be made. 2. Section 1.381(c)(22)-1 This notice of proposed rulemaking proposes to remove §1.381(c)(22)1(b) (6) because its requirement that an acquir ing corporation take into account any net increases or net decreases in reserves of the distributor or transferor corporation under section 810(d)(1) is no longer ap plicable. The principle in §1.381(c)(22) 1(b)(6), however, applies to transactions in which the distributor or transferor cor poration has any remaining portion of an adjustment that was required to be taken into account over 10 years under prior sec tion 807(f). See section 2.08 of Rev. Proc. 201910. After the amendment of section 807(f) by the TCJA, an acquiring corpora tion must take into account any remaining section 481(a) adjustment of the transferor or distributor corporation pursuant to the IRS’s administrative procedures. See sec tion 7.03 of Rev. Proc. 201513. 3. Section 1.817A-1 This notice of proposed rulemaking proposes to revise §1.817A1 to remove the requirement that the current market rate of interest prescribed in §1.817A1(a) (5) be used to determine both the life in surance reserve and the required interest (as provided in prior section 812(b)(2) (A)) during the temporary guarantee peri od of a nonequity indexed modified guar anteed contract (MGC). Prior to its amendment by the TCJA, section 807(d) generally provided that life insurance reserves for a contract were determined using a rate of interest appli cable when the contract was issued. Prior section 807(d)(2)(B) provided that the rate of interest to be used was the greater of the applicable Federal interest rate or the prevailing State assumed interest rate. The TCJA amended section 807(d), however, to provide that life insurance reserves for a contract are generally computed using a method applicable to the contract and in effect as of the date the reserve is de termined. Section 807(d), as amended, does not prescribe a particular interest rate to be used in determining life insur ance reserves. Thus, the requirement in §1.817A1(b)(2) that the applicable inter est rate to be used under section 807(d) (2)(B) to compute life insurance reserves for an MGC is a prescribed current mar ket interest rate is now inapplicable. Ad ditionally, the need for §1.817A1(b)(1) to prescribe a current market interest rate to determine life insurance reserves for MGCs (as opposed to an interest rate ap plicable when the contract was issued) is no longer present because section 807(d), as amended, requires the use of a method in effect as of the date the reserve is de termined. Prior to its amendment by the TCJA, section 812 determined “company’s share” and “policyholder’s share,” in part, by reference to required interest on cer tain reserves under section 807(c). Prior section 812(b)(2)(A) provided that the re quired interest was computed at the greater of the prevailing State assumed rate or the applicable Federal interest rate. The TCJA amended section 812 to provide that the “company’s share” means 70% and the “policyholder’s share” means 30%. Ac cordingly, after the TCJA’s amendment of section 812, a particular interest rate is no longer needed to determine the “com pany’s share” and the “policyholder’s share.” Section 1.817A1 also requires that the current market rate of interest prescribed in §1.817A1(a)(5) be used to determine reserves under section 807(c)(3) for an MGC during any temporary guarantee period. Prior to amendment of section 807(c), the “appropriate rate of interest” that was otherwise required to determine reserves for MGCs under section 807(c) (3) (the highest of the applicable Federal interest rate, the prevailing State assumed interest rate, or the interest rate assumed by the company in determining the guar anteed benefit) was determined when the obligation first did not involve life, ac cident, or health contingencies, and was thus not necessarily a current interest rate. The TCJA, however, modified the flush language in section 807(c)(3) to provide that the “appropriate rate of interest” is the highest rate or rates permitted to be used to discount the obligations by the NAIC as of the date the reserve is determined. Be cause the interest rate now required to be used to determine reserves under section 807(c)(3) (in the absence of the application of §1.817A1) is a current market interest rate, §1.817A1 may no longer be need ed to provide a current interest rate. The Treasury Department and the IRS request comments on whether the current market rate of interest prescribed by §1.817A1 should continue to apply to reserves under section 807(c)(3) for an MGC during any temporary guarantee period. 4. Section 1.338-11 This notice of proposed rulemaking proposes to revise §1.33811(d)(2) to re flect the change in section 807(f) made by the TCJA. Section 1.33811(d) gen erally provides that when a section 338 election is made for an insurance compa ny, new target must effectively capitalize its subsequent increase in reserves for any acquired contracts in the deemed as set sale to the extent the fair market value of certain assets acquired by new target in the deemed asset sale exceeds the ad justed grossedup basis (AGUB) allocat ed to those assets (that is, to the extent of a “bargain purchase”). In the absence of Bulletin No. 2020–17 675 April 20, 2020 this rule, new target could obtain a better tax result if it acquired understated re serves and subsequently increased them rather than acquiring adequately stated reserves. Section 1.33811(d) was intended to minimize incentives for sellers to defer increases in reserves. See T.D. 9257 (71 FR 17990). An exception to §1.33811(d), however, is provided if new target is re quired by section 807(f) to spread the re serve increase over the 10 succeeding tax able years. See §1.33811(d)(2)(ii). There was limited incentive for sellers to defer increases in reserves when new target was required to spread the deduction resulting from the reserve increase over 10 years, as was the case under section 807(f) pri or to its amendment by the TCJA. The amendment to section 807(f) by the TCJA together with the applicable adminis trative procedures require a deduction resulting from a reserve increase under section 807(f) to be taken into account in one year. As a result, there is greater in centive for a seller to defer increases in reserves if new target would be allowed to take the deduction into account in one year, and the reason for providing the ex ception currently in §1.33811(d)(2)(ii) no longer exists. Accordingly, this notice of proposed rulemaking proposes to remove the exception for reserve increases under section 807(f) that is currently provided in §1.33811(d)(2)(ii). A new §1.33811(d)(3)(iii) is also pro posed to be added so the standard used for determining when there is an addi tional premium under §1.33811(d)(3) for a change in items referenced in sec tion 807(c) is the same as that used under section 807(f). Changes in PBRs that are contemplated by the applicable method, for example, may not constitute changes in the basis of computing reserves under section 807(f) and should not result in an amount of additional premium under §1.33811(d)(3). G. Proposed Conforming Changes to Regulations. This notice of proposed rulemaking proposes to revise §§1.8012, 1.8095, and 1.8481 to correct references to Code provisions or regulations that have been changed, removed, or are proposed to be removed by this notice of proposed rulemaking. Determination of Life Insurance or Annuity Contract Status for Certain Foreign-Issued Contracts The Code contains a statutory defi nition of a life insurance contract under section 7702, rules applicable to certain flexible premium contracts under section 101(f), distribution on death requirements under section 72(s), and diversification requirements under section 817(h). These requirements, which reflect Congress’s concern that the taxfavored treatment generally accorded life insurance and an nuity contracts was available to contracts that were too investment oriented or pro vided for undue tax deferral, are relevant to the tax treatment of a policyholder, an nuitant, or beneficiary as well as the entity that issues or reinsures a life insurance or annuity contract. The Treasury Department and IRS re ceived a request to promulgate regulations under section 807 that generally would provide, for purposes of subchapter L, that the determination of whether a con tract issued by a nonUnited States insur ance company and reinsured by a United States insurance company is a life insur ance or annuity contract is made without regard to these statutory requirements, provided that (i) no policyholder, insured, annuitant, or beneficiary with respect to the contract is a United States person and (ii) such contract is regulated as a life in surance or annuity contract by a foreign regulator. Under the requested approach, a United States insurance company may be able to establish additional life insurance or other tax reserves for such a contract that is reinsured by a United States insur ance company even if the contract does not meet these statutory requirements. The Treasury Department and the IRS are evaluating this request, includ ing whether to address it as part of this rulemaking. Comments are requested gen erally in respect of the requested change, including in respect of statutory interpre tation and implications in various contexts and provisions outside of subchapter L, such as, for example, the interaction with policies underlying the Federal withhold ing tax provisions that could apply to re insurance payments from a United States reinsurer to a nonUnited States insurer as well as the administrability of requiring a United States reinsurance company to track the residence of direct and indirect beneficial owners of any interest in the contract, policyholder, insured, annuitant, or beneficiary of a contract issued by a nonUnited States insurance company that it may not administer. Proposed Applicability Dates The rules in this notice of proposed rulemaking are proposed to apply to tax able years beginning on or after the date of publication of the Treasury decision adopting these rules as final regulations in the Federal Register. A taxpayer may choose to apply §§1.8074, 1.8161, and 1.817A1(b) of the final regulations to taxable years be ginning after December 31, 2017, the ef fective date of the revision of section 807 made by the TCJA, and ending before the first taxable year that begins on or after the date of publication of the Treasury de cision adopting these rules as final in the Federal Register. See section 7805(b) (7). Alternatively, a taxpayer may rely on §§1.8074 and 1.8161 of the proposed regulations for taxable years beginning af ter December 31, 2017, and ending before the first taxable year that begins on or after the date of publication of the Treasury de cision adopting these rules as final in the Federal Register. Under proposed §1.60122(l), taxpay ers may choose to apply §1.60122(c) of the final regulations to any original Fed eral income tax return (including any amended return filed on or before the due date (including extensions) of such origi nal return) timely filed on or after the date of publication of the Treasury decision adopting these rules as final in the Feder- al Register. Effect on Other Documents The following revenue rulings are pro posed to be obsoleted for taxable years be ginning on or after the date of publication of the Treasury decision adopting these rules as final regulations in the Federal Register: Rev. Rul. 20026, Rev. Rul. 94 74, Rev. Rul. 80117, Rev. Rul. 80116, April 20, 2020 676 Bulletin No. 2020–17 Rev. Rul. 78354, Rev. Rul. 77198, Rev. Rul. 75308, Rev. Rul. 7457, Rev. Rul. 70568, Rev. Rul. 70192, Rev. Rul. 69 444, Rev. Rul. 65240, Rev. Rul. 65233, Rev. Rul. 65143. Comments are request ed regarding principles contained within these revenue rulings that are consistent with current section 807(f) and for which additional guidance is needed if these rul ings are obsoleted. Notice 201029 is proposed to be ob soleted for taxable years beginning after December 31, 2017. Special Analyses This regulation is not subject to review under section 6(b) of Executive Order 12866 pursuant to the Memorandum of Agreement (April 11, 2018) between the Treasury Department and the Office of Management and Budget regarding re view of tax regulations. Paperwork Reduction Act The collection of information relating to this notice of proposed rulemaking will be submitted to the Office of Management and Budget for review under OMB Con trol Number 15450123 in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)). In response to the Conference Report, §1.60122 of the proposed regulations would require an insurance company to include the insurance company’s annual statement (as defined in §1.60122(c)(5)) with an electronically filed Federal in come tax return (Form 1120L for a life insurance company and Form 1120PC for a nonlife insurance company). Federal income tax items of an insurance compa ny are determined in part based upon the insurance company’s annual statement. Providing the annual statement to the IRS with an electronically filed Federal in come tax return is necessary to allow the IRS to better and more efficiently examine an insurance company’s Federal income tax return. In accordance with section 807(e) (6), as added by the TCJA, §1.8073 of the proposed regulations provides that the IRS may require reporting on Form 1120L of the opening balance and clos ing balance of items described in sec tion 807(c) (for example, life insurance reserves) and the method of computing such items for purposes of determining income. Providing this information is necessary to allow the IRS to better ex amine an insurance company’s Federal income tax return. For purposes of the Paperwork Reduc tion Act, the burden for the collection of information associated with §1.60122 of the proposed regulations will be reflected in the burden on the Form 1120L and in the burden on the Form 1120PC (OMB Control Number 15450123) when the burden for each is revised to reflect the collection of information associated with §1.60122 of the proposed regulations. The respondents to the collection of infor mation are life insurance companies that file the Form 1120L electronically and nonlife insurance companies that file the Form 1120PC electronically. For purposes of the Paperwork Reduc tion Act, the burden for the collection of information associated with §1.8073 of the proposed regulations will be reflected in the burden on the Form 1120L (OMB Control Number 15450123) when the burden is revised to reflect the collection of information associated with §1.8073 of the proposed regulations. The respon dents to the collection of information are life insurance companies that file a Form 1120L. Comments on the collection of infor mation should be sent to the Office of Management and Budget, Attn: Desk Officer for the Department of the Trea sury, Office of Information and Regula tory Affairs, Washington, DC 20503, with copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, SE: CAR:MP:T:T:SP, Washington, DC 20224. Comments on the collection of informa tion should be received by June 1, 2020. Comments are specifically requested con cerning: Whether the proposed collection of in formation is necessary for the proper per formance of the functions of the IRS, in cluding whether the information will have practical utility; How the quality, utility, and clarity of the information to be collected may be en hanced; How the burden of complying with the proposed collection of information may be minimized, including through the application of automated collection tech niques or other forms of information tech nology; and Estimates of capital or startup costs and costs of operation, maintenance, and purchase of services to provide informa tion. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it dis plays a valid control number assigned by the Office of Management and Budget. Regulatory Flexibility Act It is hereby certified that the proposed regulations will not have a significant eco nomic impact on a substantial number of small entities pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6). Section 13517 of the TCJA added sec tion 807(e)(6) to the Code. Under section 807(e)(6), the Secretary may require re porting (at such time and in such manner as the Secretary shall prescribe) with re spect to the opening balances and the clos ing balances of reserves and with respect to the method of computing reserves for purposes of determining income. Section 1.8073 of the proposed regulations would allow the IRS to require the reporting of this information on any prescribed forms, such as the Form 1120L. The Conference Report at 478479 provides that, under existing authority, the Secretary may require an insurance company to provide its annual statement via a link, electronic copy, or other sim ilar means. Section 1.60122(c) of the proposed regulations would require an insurance company to include the insur ance company’s annual statement with an electronically filed Federal income tax return (Form 1120L for a life insurance company and Form 1120PC for a non life insurance company). Under current procedures, an insurance company can only electronically file a Form 1120L or Form 1120PC if the insurance compa ny is part of an affiliated group filing a consolidated return, the parent of which files a Form 1120. Although data are not readily available, the IRS and the Trea sury Department expect that any report ing burden associated with §1.60122(c) of the proposed regulations will fall pri Bulletin No. 2020–17 677 April 20, 2020 marily on financial and insurance firms with annual receipts greater than $41.5 million and, therefore, will not affect a substantial number of small entities. See 13 CFR 121.201, sector 52 (finance and insurance). As stated in the preceding paragraph, the rule is not expected to affect a substan tial number of small entities; however, even if a substantial number of small en tities were affected, the economic impact of the regulation is not likely to be sig nificant. Section 1.8073 of the proposed regulations is limited in scope to time and manner of information reporting, and any economic impact associated with this pro posed regulation is expected to be mini mal. Further, the information reported to the IRS is information that the insurance company has readily available. Notwithstanding this certification, the Treasury Department and the IRS invite comments on the impact this rule would have on small entities. Pursuant to section 7805(f) of the Code, the notice of proposed rulemaking will be submitted to the Chief Counsel for Advocacy of the Small Business Adminis tration for comment on its impact on small business. Comments and Public Hearing Before these proposed regulations are adopted as final regulations, consideration will be given to any comments that are submitted timely to the IRS as prescribed in this preamble under the ADDRESSES heading. The Treasury Department and the IRS request comments on all aspects of the proposed rules and the other pro posed actions described herein. All com ments that are submitted by the public will be available for public inspection and copying at http://www.regulations.gov or upon request. A public hearing will be scheduled if requested in writing by any person that timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the hearing will be published in the Federal Register. Drafting Information The principal author of these regula tions is Dan Phillips, Office of Associate Chief Counsel (Financial Institutions and Products), IRS. However, other personnel from the Treasury Department and the IRS participated in their development. Statement of Availability of IRS Documents The IRS notices, revenue procedures, and revenue rulings cited in this pream ble are published in the Internal Revenue Bulletin (or Cumulative Bulletin) and are available from the Superintendent of Doc uments, U.S. Government Publishing Of fice, Washington, DC 20402, or by visit ing the IRS website at http://www.irs.gov. List of Subjects 26 CFR Part 1 Income taxes, Reporting and record keeping requirements. 26 CFR Part 301 Employment taxes, Estate taxes, Ex cise Taxes, Gift taxes, Income taxes, Penalties, Reporting and recordkeeping requirements. Proposed Amendments to the Regulations Accordingly, 26 CFR parts 1 and 301 are proposed to be amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 is amended by adding a sectional authority for §1.8073 in numerical order to read in part as follows: Authority: 26 U.S.C. 7805 * * * * * * * * Section 1.8073 also issued under 26 U.S.C. 807(e)(6). * * * * * §1.338-11 [Amended] Par. 2. Section 1.33811 is amended by: 1. Revising paragraph (d)(2). 2. Removing the language “and (d)(3) (iii)” from the first sentence in paragraph (d)(3)(i) and adding “through (iv)” in its place. 3. Redesignating paragraph (d)(3)(iii) as paragraph (d)(3)(iv). 4. Adding a new paragraph (d)(3)(iii). 5. Revising newly redesignated para graph (d)(3)(iv). 6. Adding paragraph (d)(7)(iii). The revisions and additions read as fol lows: §1.338-11 Effect of section 338 election on insurance company targets. * * * * * (d) * * * (2) Exception. New target is not treat ed as receiving additional premium under paragraph (d)(1) of this section if it is un der state receivership as of the close of the taxable year for which the increase in re serves occurs. (3) * * * * * (iii) Increases in section 807(c) re- serves. The positive amounts with respect to the items referred to in section 807(c) other than discounted unpaid loss reserves is the sum of the net increases in such items that are required to be taken into ac count under section 807(f). (iv) Increases in other reserves. The positive amount with respect to reserves other than discounted unpaid loss re serves and other items referred to in sec tion 807(c) is the net increase of those reserves due to changes in estimate, methodology, or other assumptions used to compute the reserves (including the adoption by new target of a methodology or assumptions different from those used by old target). * * * * * (7) * * * (iii) Application of paragraphs (d)(2) and (3) of this section. Paragraphs (d) (2) and (3) of this section apply to tax able years beginning on or after [DATE FINAL REGULATIONS ARE PUB- LISHED IN THE FEDERAL REGIS- TER]. For taxable years beginning before such date, see paragraph (d) of this section as contained in 26 CFR part 1 revised as of April 1, 2019. * * * * * §1.381(c)(22)-1 [Amended] Par. 3. In §1.381(c)(22)1, paragraph (b)(6) is removed and reserved. April 20, 2020 678 Bulletin No. 2020–17 §1.801-2 [Amended] Par. 4. Section 1.8012 is amended by removing the language “1.8017” and adding the language “1.8016” in its place. Par. 5. Section 1.8015 is amended by: 1. Removing paragraph (c) and redes ignating paragraph (d) as paragraph (c). 2. In newly redesignated paragraph (c), designating the Example as paragraph (c) (1). 3. In newly designated paragraph (c) (1): i. Designating the introductory text as paragraph (c)(1)(i). ii. Adding a heading for the table in newly designated paragraph (c)(1)(i). iii. Designating the undesignated para graph following newly designated para graph (c)(1)(i) as paragraph (c)(1)(ii). 4. Adding reserved paragraph (c)(2). The addition reads as follows: §1.801-5 [Amended] * * * * * (c) * * * (1) * * * (i) * * * Table 1 to Paragraph (c)(1)(i) * * * * * §1.801-7 [Removed and Reserved] Par. 6. Section 1.8017 is removed and reserved. §1.801-8(e) [Amended] Par. 7. In §1.8018, paragraph (e) is re moved and reserved. §1.806-4 [Removed] Par. 8. Section 1.8064 is removed. Par. 9. Section 1.8071 is revised to read as follows: §1.807-1 Computation of life insurance reserves. (a) No asset adequacy reserve. The life insurance reserve determined under section 807(d)(1) does not include any asset ade quacy reserve. An asset adequacy reserve includes any reserve that is established as an additional reserve based upon an analy sis of the adequacy of reserves that would otherwise be established or any reserve that is not held with respect to a particular contract. In determining whether a reserve is a life insurance reserve, the label placed on such reserve is not determinative, pro vided, however, any reserve or portion of a reserve that would have been established pursuant to an asset adequacy analysis re quired by the National Association of In surance Commissioner’s Valuation Manual 30 as it existed on December 22, 2017, the date of enactment of Public Law 11597, is an asset adequacy reserve. (b) Applicability date. The rules of this section apply to taxable years beginning on or after [DATE FINAL REGULA- TIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. Par. 10. Section 1.8073 is added to read as follows: §1.807-3 Reporting of reserves. (a) Reserve reporting. A life insurance company subject to tax under section 801 is required to make a return on Form 1120 L, U.S. Life Insurance Company Income Tax Return. The Internal Revenue Service may require reporting with respect to the opening balance and closing balance of items described in section 807(c) and with respect to the method of computing such items for purposes of determining income. Such reporting may provide for the man ner in which separate account items are re ported. (See section 6011 and §301.6011 1 of this chapter.) (b) Applicability date. The rules of this section apply to taxable years beginning on or after [DATE FINAL REGULA- TIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. Par. 11. Section 1.8074 is added to read as follows: §1.807-4 Adjustment for change in computing reserves. (a) Requirement to follow administra- tive procedures. Except as provided in §1.4461(e), a change in basis of comput ing an item referred to in section 807(c) is a change in method of accounting for purposes of §1.4461(e). Before comput ing such item under a new basis, a life in surance company must obtain the consent of the Commissioner of Internal Revenue or his delegate (Commissioner) pursuant to administrative procedures prescribed by the Commissioner. Similarly, an insur ance company other than a life insurance company (a nonlife insurance company) that changes its basis of computing life in surance reserves must obtain the consent of the Commissioner pursuant to adminis trative procedures prescribed by the Com missioner. (b) Section 481 adjustment—(1) In general. If the basis of computing any item referred to in section 807(c) as of the close of any taxable year (the year of change) differs from the basis of comput ing such item at the close of the preceding taxable year, then the difference between the amount of the item at the close of the taxable year computed on the new basis and the amount of the item at the close of the taxable year computed on the old basis that is attributable to contracts issued be fore the taxable year, is taken into account under section 481 and §§1.4811 through 1.4815 as an adjustment attributable to a change in method of accounting. (2) Loss of company status. If for any taxable year a taxpayer that was an in surance company for the year of change is no longer an insurance company, then the taxpayer must take into account in the preceding taxable year (that is, the last taxable year it was an insurance compa ny) the balance of any section 481(a) ad justment determined under paragraph (b) (1) of this section. A taxpayer that was an insurance company for the year of change does not accelerate the balance of any sec tion 481(a) adjustment determined under paragraph (b)(1) of this section merely because it changes from a life insurance company to a nonlife insurance company or because it changes from a nonlife in surance company to a life insurance com pany. (c) Effect on determining increase or decrease in reserves—(1) Effect under section 807(a) and (b). If there is a change in basis of computing any item described in section 807(c) for a taxable year, then, for purposes of section 807(a) and (b), the closing balance for such item for the year of change with respect to contracts issued before the year of change is determined on the old basis and the opening balance for such item for the next taxable year for Bulletin No. 2020–17 679 April 20, 2020 such contracts is computed on the new ba sis. (2) Effect under section 832. The fol lowing rules apply for purposes of section 832(b)(4): (i) For the year of change, life insur ance reserves at the end of the year of change with respect to contracts issued before the year of change are determined on the old basis. (ii) For the taxable year following the year of change, life insurance reserves at the end of the preceding taxable year (that is, the year of change) with respect to con tracts issued before the year of change are determined on the new basis. (d) Examples. The principles of para graphs (a) through (c) of this section are illustrated by the following examples. For purposes of these examples and ex cept as otherwise provided, IC is a life insurance company within the meaning of section 816(a) that issues life insur ance and annuity contracts. IC is required to determine the amount of life insurance reserves under section 807(d) and to take net increases or decreases in the reserves into account in computing life insurance company taxable income. IC’s reserve for each insurance contract at issue exceeds the net surrender value for such contract and does not exceed the statutory reserve for such contract. IC uses a calendar year as its taxable year. (1) Example 1—(i) Facts. In 2021, IC discovered that it had computed the amount of life insurance re serves for its 2019 and 2020 taxable years by using a mortality table that was not permitted by the tax reserve method (as defined in section 807(d)(3)). (ii) Analysis. To comply with section 807(d), IC must use the appropriate mortality table to compute its life insurance reserves for the 2021 taxable year. This change is a change in basis of computing life insurance reserves and a change in method of ac counting described in §1.4461(e). IC is required to obtain the consent of the Commissioner to change its basis of computing its life insurance reserves by following the administrative procedures prescribed by the Commissioner. (2) Example 2—(i) Facts. IC issues variable an nuity contracts with guaranteed minimum benefits. In Year 1, the National Association of Insurance Commissioners makes a change to the Commission ers’ Annuity Reserve Valuation Method that impos es a new computational requirement on issuers of variable annuities with guaranteed minimum ben efits. The requirement applies to the determination of statutory reserves as of December 31, Year 1, for contracts issued on or prior to December 31, Year 1. (ii) Analysis. To comply with section 807(d), IC must compute its life insurance reserves for variable annuities with guaranteed minimum benefits for the Year 1 taxable year using the new computational requirement. This change is a change in basis of computing life insurance reserves for such contracts issued prior to Year 1 and a change in method of ac counting described in §1.4461(e). IC is required to obtain the consent of the Commissioner to change its basis of computing its life insurance reserves by following the administrative procedures prescribed by the Commissioner. (3) Example 3—(i) Facts. In 2021, IC changed the basis of computing the amount of life insurance reserves for a certain type of life insurance contract as described in section 807(f). Both the basis used for computing the reserves for the relevant contracts at the close of the 2020 taxable year (old basis) and the basis of computing the reserves for the relevant type of contract at the close of the 2021 taxable year (new basis) are consistent with the applicable Com missioners’ Reserve Valuation Method. IC followed the administrative procedures prescribed by the Commissioner to obtain consent to change the basis of computing these reserves. IC determined that the life insurance reserves as of December 31, 2021, for the relevant contracts issued prior to 2021 were $110 if computed using the old method and $120 if com puted using the new method. IC also determined that the life insurance reserves as of December 31, 2021, for the relevant contracts issued during 2021 were $15 using the new basis. (ii) Analysis. IC must take into account under section 481 and the administrative procedures pre scribed by the Commissioner the $10 difference be tween the reserves for the relevant contracts issued prior to 2021 computed under the old basis ($110) and the reserves for such contracts computed under the new basis ($120). For purposes of determining any net increase or net decrease in reserves in taxable year 2021 under section 807(a) or (b), IC’s closing balance of life insurance reserves computed under section 807(d) with respect to the relevant contracts is $110 for contracts issued prior to 2021 (computed on the old basis) and $15 for contracts issued during 2021 (computed on the new basis). IC’s opening bal ance in 2022 for life insurance reserves for the rele vant contracts is $135 (computed on the new basis). (4) Example 4—(i) Facts. The facts are the same as in paragraph (d)(3) of this section (the facts in Example 3), except that IC is an insurance company that is not a life insurance company. IC is required to compute taxable income under section 832. (ii) Analysis. IC must take into account under section 481 and the administrative procedures pre scribed by the Commissioner the $10 difference be tween the reserves for the relevant contracts issued prior to 2021 computed under the old basis ($110) and the reserves for such contracts computed under the new basis ($120). For purposes of determining the premiums earned on insurance contracts during the taxable year as described in section 832(b)(4) for the year of change, the life insurance reserves at the end of the taxable year are $110 for contracts issued prior to 2021 (computed on the old basis) and $15 for contracts issued during 2021 (computed on the new basis). For purposes of determining the premi ums earned on insurance contracts during the taxable year as described in section 832(b)(4) for the taxable year following the year of change, the life insurance reserves at the end of the preceding taxable year (the year of change) with respect to relevant contracts are $135 (computed on the new basis). (e) Applicability date. The rules of this section apply to taxable years beginning on or after [DATE FINAL REGULA- TIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. However, a taxpayer may choose to apply the rules of this section for taxable years begin ning after December 31, 2017, the effec tive date of the revision of section 807 by Public Law 11597, and ending before the first taxable year that begins on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. See section 7805(b)(7). §1.809-2 [Removed] Par. 12. Section 1.8092 is removed. §1.809-5 [Amended] Par. 13. Section 1.8095 is amended by removing the language “and §1.8103” from the last sentence of paragraph (a)(5)(iii). §1.810-3 [Removed] Par. 14. Section 1.8103 is removed. Par. 15. Section 1.8161 is added before the undesignated center heading “Miscel laneous Provisions” to read as follows: §1.816-1 Life insurance reserves. (a) Definition of life insurance reserves. Except as provided in section 816(h), a reserve that meets the requirements of section 816(b)(1) and (2) will not be dis qualified as a life insurance reserve solely because the method used to compute the reserve takes into account other factors, provided that the method used to compute the reserve is a tax reserve method as de fined in section 807(d)(3) and that such reserve is not an asset adequacy reserve as described in §1.8071(a). (b) Applicability date. The section applies to taxable years beginning on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. However, a taxpayer may choose to apply the rules of this section for taxable years beginning after Decem ber 31, 2017, the effective date of the revi sion of section 807 by Public Law 11597, April 20, 2020 680 Bulletin No. 2020–17 and ending before the first taxable year that begins on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. See section 7805(b)(7). §1.817A-0 [Removed] Par. 16. Section 1.817A0 is removed. Par. 17. Section 1.817A1 is amended by: 1. Revising the heading to paragraph (b) and paragraph (b)(1). 2. Removing paragraph (b)(2). 3. Redesignating paragraphs (b)(3) and (4) as paragraph (b)(2) and (3). 5. In newly redesignated paragraph (b) (3): i. Revising the first sentence. ii. Removing the word “None” in the second sentence and adding “Neither” in its place. 6. Removing paragraph (b)(5) 7. Revising paragraph (d). The revisions read as follows: §1.817A-1 Certain modified guaranteed contracts. * * * * * (b) Applicable interest rates for certain non-equity-indexed modified guaranteed contracts—(1) Tax reserves during tempo- rary guarantee period under section 807(c) (3). An insurance company is required to determine the tax reserves for certain MGCs under section 807(c)(3). During the temporary guarantee period of such an MGC that is a nonequityindexed MGC, the applicable interest rate to be used is the current market rate, as defined in paragraph (a)(5) of this section. For periods after the end of such a temporary guarantee period, section 807(c)(3) is not modified when ap plied to a nonequity indexed MGC. Sec tion 807(c)(3) is not affected by the defi nition of current market rate contained in paragraph (a)(5) of this section once the temporary guarantee period has expired. * * * * * (3) Periods after the end of the tempo- rary guarantee period. For periods after the end of the temporary guarantee peri od, sections 807(c)(3) and 811(d) are not modified when applied to nonequityin dexed MGCs. * * * * * * * * (d) Applicability dates. Paragraph (b) of this section applies to taxable years beginning on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. How ever, a taxpayer may choose to apply the rules of paragraph (b) of this section for taxable years beginning after December 31, 2017, the effective date of the revision of section 807 by Public Law 11597, and ending before the first taxable year that begins on or after [DATE FINAL REGU- LATIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. See section 7805(b)(7). For taxable years beginning before [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER], see paragraph (b) of this section as contained in 26 CFR part 1 re vised as of April 1, 2019. §1.818-2 [Amended] Par. 18. Section 1.8182 is amended by removing paragraph (c). §1.818-4 [Removed and Reserved] Par. 19. Section 1.8184 is removed and reserved. §1.848-1 [Amended] Par. 20. Section 1.8481 is amended by removing the language “section 807(e) (4)” in paragraph (b)(2)(i) and adding the language “section 807(e)(3)” in its place. Par. 21. Section 1.60122 is amended by: 1. In the second sentence of paragraph (c)(1)(i), removing “Except as provided in paragraph (c)(4) of this section, such” and adding “Such” in its place. 2. In the third sentence of paragraph (c)(2), removing “Except as provided in paragraph (c)(4) of this section, such” and adding “Such” in its place. 3. Removing paragraph (c)(4). 4. Redesignating paragraph (c)(5) as paragraph (c)(4). 5. Revising paragraph (l). The revision reads as follows. §1.6012-2 Corporations required to make returns of income. * * * * * (l) Applicability date. Except as pro vided in this paragraph (l), paragraph (c) of this section applies to any taxable year beginning on or after [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER]. How ever, a taxpayer may choose to apply para graph (c) of this section to any original Federal income tax return (including any amended return filed on or before the due date (including extensions) of such origi nal return) timely filed on or after [DATE FINAL REGULATIONS ARE PUB- LISHED IN THE FEDERAL REGIS- TER]. For taxable years beginning be fore [DATE FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER] see paragraph (c) of this section as contained in 26 CFR part 1 in effect on April 1, 2019. PART 301—PROCEDURE AND ADMINISTRATION Par. 22. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * §301.9100-6T [Amended] Par. 25. Section 301.91006T is amend ed by: 1. Removing from the table in para graph (a)(1) the three entries for “211” and the entries for “216(c)(1),” “216(c) (2),” “217(i),” and “217(l)(2)(B).” 2. Removing and reserving paragraph (a)(2)(iii). 3. Removing paragraph (a)(3)(v). 4. In paragraph (a)(4): i. Removing “211 (Code section 810(b) (3)), 216(c) (1) and (2), 217(l),” from the first sentence. ii. Removing “211 (Code sections 806(d)(4), and 807(d)(4)(C)), 217(i),” from the second sentence. iii. Removing the last sentence. Sunita Lough, Deputy Commissioner for Services and Enforcement. (Filed by the Office of the Federal Register on April 1, 2019, 8:45 a.m., and published in the issue of the Federal Register for April 2, 2019, 85 F.R. 18496) Bulletin No. 2020–17 i April 20, 2020 Definition of Terms Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect: Amplified describes a situation where no change is being made in a prior pub lished position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle ap plied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below). Clarified is used in those instances where the language in a prior ruling is be ing made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior rul ing is being changed. Distinguished describes a situation where a ruling mentions a previously pub lished ruling and points out an essential difference between them. Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above). Obsoleted describes a previously pub lished ruling that is not considered deter minative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted. Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling. Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the sub stance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previous ly published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded. Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rul ings in the series. Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cas es in litigation, or the outcome of a Ser vice study. Abbreviations The following abbreviations in current use and formerly used will appear in material published in the Bulletin. A—Individual. Acq.—Acquiescence. B—Individual. BE—Beneficiary. BK—Bank. B.T.A.—Board of Tax Appeals. C—Individual. C.B.—Cumulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Cooperative. Ct.D.—Court Decision. CY—County. D—Decedent. DC—Dummy Corporation. DE—Donee. Del. Order—Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statement of Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. April 20, 2020 ii Bulletin No. 2020–17 Numerical Finding List 1 Bulletin 2020–17 AOD: 20201, 202012 I.R.B. 521 20202, 202014 I.R.B. 558 20203, 202017 I.R.B. 663 Announcements: 20201, 20205 I.R.B. 552 20202, 202015 I.R.B. 609 20203, 202015 I.R.B. 655 20204, 202017 I.R.B. 667 Notices: 20201, 20202 I.R.B. 290 20202, 20203 I.R.B. 327 20203, 20203 I.R.B. 330 20204, 20204 I.R.B. 380 20205, 20204 I.R.B. 380 20206, 20207 I.R.B. 411 20207, 20207 I.R.B. 411 20208, 20207 I.R.B. 415 20209, 20207 I.R.B. 417 202010, 202010 I.R.B. 456 202011, 202011 I.R.B. 492 202012, 202011 I.R.B. 495 202013, 202011 I.R.B. 502 202014, 202013 I.R.B. 555 202015, 202014 I.R.B. 559 202016, 202014 I.R.B. 559 202017, 202015 I.R.B. 590 202018, 202015 I.R.B. 590 202019, 202015 I.R.B. 591 202020, 202016 I.R.B. 660 202021, 202016 I.R.B. 660 202022, 202017 I.R.B. 664 Proposed Regulations: REG10743119, 20203 I.R.B. 332 REG12218018, 20203 I.R.B. 342 REG10095619, 20204 I.R.B. 383 REG12571018, 20205 I.R.B. 554 REG13274117, 202010 I.R.B. 458 REG10081419, 202012 I.R.B. 542 REG13252917, 202012 I.R.B. 667 Revenue Procedures: 20201, 202001 I.R.B. 1 20202, 202001 I.R.B. 107 20203, 202001 I.R.B. 131 20204, 202001 I.R.B. 148 20205, 202001 I.R.B. 241 20207, 202001 I.R.B. 281 Revenue Procedures:—Continued 20209, 202002 I.R.B. 294 202010, 202002 I.R.B. 295 202011, 202006 I.R.B. 406 20208, 202008 I.R.B. 447 202012, 202011 I.R.B. 511 202013, 202011 I.R.B. 515 202017, 202012 I.R.B. 539 202018, 202015 I.R.B. 592 202014, 202016 I.R.B. 661 Revenue Rulings: 20201, 20203 I.R.B. 296 20202, 20203 I.R.B. 298 20203, 20203 I.R.B. 409 20204, 20204 I.R.B. 444 20205, 20205 I.R.B. 454 20206, 202011 I.R.B. 490 20207, 202012 I.R.B. 522 20209, 202015 I.R.B. 563 202010, 202015 I.R.B. 565 Treasury Decisions: 9886, 20202 I.R.B. 285 9887, 20203 I.R.B. 302 9888, 20203 I.R.B. 306 9891, 20208 I.R.B. 419 9892, 20208 I.R.B. 439 9893, 20209 I.R.B. 449 9895, 202015 I.R.B. 565 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin 2018–52, dated December 27, 2018. Bulletin No. 2020–17 iii April 20, 2020 Finding List of Current Actions on Previously Published Items 1 Bulletin 2020–17 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin 2018–52, dated December 27, 2018. Internal Revenue Service Washington, DC 20224 Official Business Penalty for Private Use, $300 INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available at www.irs.gov/irb/. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR6230 Washington, DC 20224.
Setzen Sie Ihre Recherche in ChatGPT oder Claude fort
Verbinden Sie Omnilex, um den Rechtskorpus über Ihren KI-Assistenten zu durchsuchen.