The US Internal Revenue Service (“IRS”) has just released Notice 2018-41, in which it previews regulations to be issued under the new life settlement reporting regime enacted as part of the Tax Cut and Jobs Act in 2017. The good news is that reporting will be required only after the IRS finalizes regulations and issues forms. But reporting will be required for all 2018 transactions, even if undertaken prior to the time that regulations and forms are issued. In addition, the IRS has invited industry comments on aggregating broker transactions with transactions to the ultimate owner. Mark Leeds and Brennan Young of Mayer Brown’s New York office analyze the Notice in the attached Legal Update.
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