§6050V — Title 26 Internal Revenue Code | U.S. Code

§6050V Returns Relating to Applicable Insurance Contracts in Which Certain Exempt Organizations Hold Interests

Title 26 › Subtitle Subtitle F— Procedure and Administration › Chapter 61— INFORMATION AND RETURNS › Subchapter A— Returns and Records › Part III— INFORMATION RETURNS › Subpart B— Information Concerning Transactions With Other Persons › § 6050V

Last updated Apr 6, 2026|Official source

Summary

Charities and certain other tax-exempt organizations had to file a report with the IRS when they acquired an interest in life insurance, annuity, or endowment contracts as part of a structured deal involving a pool of such contracts shared with non-exempt investors. The report had to give the names, addresses, and taxpayer ID numbers of the organization and the insurer. Contracts where the other holders had a true insurable interest, or were only named beneficiaries or gratuitous trust beneficiaries, did not have to be reported. By its own terms, this reporting rule applied only to acquisitions made within 2 years after the section was enacted, so it remains in the law but has no current effect.

Title 26, §6050V

Internal Revenue Code — Source: USLM XML via OLRC

(a)Each applicable exempt organization which makes a reportable acquisition shall make the return described in subsection (c).

(b)Any applicable exempt organization required to make a return under subsection (a) shall file such return at such time as may be established by the Secretary.

(c)A return is described in this subsection if such return—

(1)is in such form as the Secretary prescribes,

(2)contains the name, address, and taxpayer identification number of the applicable exempt organization and the issuer of the applicable insurance contract, and

(3)contains such other information as the Secretary may prescribe.

(d)For purposes of this section—

(1)The term “reportable acquisition” means the acquisition by an applicable exempt organization of a direct or indirect interest in any applicable insurance contract in any case in which such acquisition is a part of a structured transaction involving a pool of such contracts.

(2)(A)The term “applicable insurance contract” means any life insurance, annuity, or endowment contract with respect to which both an applicable exempt organization and a person other than an applicable exempt organization have directly or indirectly held an interest in the contract (whether or not at the same time).

(B)Such term shall not include a life insurance, annuity, or endowment contract if—

(i)all persons directly or indirectly holding any interest in the contract (other than applicable exempt organizations) have an insurable interest in the insured under the contract independent of any interest of an applicable exempt organization in the contract,

(ii)the sole interest in the contract of an applicable exempt organization or each person other than an applicable exempt organization is as a named beneficiary, or

(iii)the sole interest in the contract of each person other than an applicable exempt organization is—

(I)as a beneficiary of a trust holding an interest in the contract, but only if the person’s designation as such beneficiary was made without consideration and solely on a purely gratuitous basis, or

(II)as a trustee who holds an interest in the contract in a fiduciary capacity solely for the benefit of applicable exempt organizations or persons otherwise described in subclause (I) or clause (i) or (ii).

(3)The term “applicable exempt organization” means—

(A)an organization described in section 170(c),

(B)an organization described in section 168(h)(2)(A)(iv), or

(C)an organization not described in paragraph (1) or (2) which is described in section 2055(a) or section 2522(a).

(e)This section shall not apply to reportable acquisitions occurring after the date which is 2 years after the date of the enactment of this section.

Notes & Related Subsidiaries

Editorial Notes

References in Text

The date of the enactment of this section, referred to in subsec. (e), is the date of enactment of Pub. L. 109–280, which was approved Aug. 17, 2006. Codification section 1211(a)(1) of Pub. L. 109–280, which directed the addition of section 6050V at the end of subpart B of part III of subchapter A of chapter 61, without specifying the act to be amended, was executed by adding section 6050V at the end of subpart B of part III of subchapter A of chapter 61 of this title, which consists of the Internal Revenue Code of 1986, to reflect the probable intent of Congress.

Statutory Notes and Related Subsidiaries

Effective Date

Pub. L. 109–280, title XII, § 1211(d), Aug. 17, 2006, 120 Stat. 1074, provided that: “The

Amendments

made by this section [enacting this section and amending section 6721 and 6724 of this title] shall apply to acquisitions of contracts after the date of enactment of this Act [Aug. 17, 2006].”