IRS Notice 2009-48 provides guidance on certain employer owned life insurance contracts and the information reporting requirements under IRC Section 6039I, which is closely related to the employer owned life insurance rules in IRC Section 101(j). The notice clarifies how employers should report the number of employees insured, total insurance in force, and compliance with notice and consent requirements for policies issued after a specified date. It helps businesses understand when they are subject to Form 8925 filing obligations and how to avoid adverse income tax treatment of employer owned death benefits by meeting statutory safeguards. For advisors working in the corporate life insurance market, knowledge of IRS Notice 2009-48 is important to ensure that key person and broad based employer owned coverage is properly documented and reported.

In everyday practice, producers encounter IRS Notice 2009-48 when they help employers implement or review key person insurance, split dollar plans, and broad based programs where the company is the policyowner and beneficiary. Advisors remind clients that they must obtain written notice and consent from insured employees before coverage is issued and that they may have to file Form 8925 annually to certify compliance. The notice provides examples and clarifications that help determine which contracts fall under the employer owned life insurance rules and how to handle policies on former employees or previously insured individuals. By staying aware of Notice 2009-48, advisors can coordinate with corporate tax advisors to maintain compliance, protect the tax favored status of death benefits, and integrate employer owned life insurance into executive benefit and business continuity planning without triggering unexpected taxation or reporting penalties.