(III) holds a specific license or credential. (E) Applicable taxpayer For purposes of this paragraph, the term applicable taxpayer has the meaning given such term under section 495. . (2) Conforming amendment Section 72(e)(5)(C) is amended by inserting or (12) after (10) . (3) Effective date The amendments made by this subsection shall apply to amounts received in taxable years beginning after December 31, 2023. (b) 10-Percent additional tax for distributions from applicable private placement life insurance or annuity contracts (1) In general Section 72(v) is amended— (A) by inserting or an applicable private placement life insurance or annuity contract (as defined in subsection (e)(12)) after a modified endowment contract (as defined in section 7702A) in paragraph(1), and (B) by inserting and applicable private placement life insurance or annuity contracts after modified endowment contracts in the heading thereof. (2) Effective date The amendments made by this subsection shall apply to amounts received in taxable years beginning after December 31, 2023. (c) Repeal of exclusion for death benefits (1) In general Section 101 is amended by adding at the end the following new subsection: (k) Exclusion not To apply (1) In general Subsection (a)(1) shall not apply to amounts received by reason of the death of the insured under an applicable private placement life or annuity contract (within the meaning of section 72(e)(12)). (2) Amounts previously included The Secretary shall prescribe rules to ensure that paragraph (1) shall not apply to any portion of any amount received which was previously included in gross income. . (2) Conforming amendment Section 101(a)(1) is amended by striking and subsection (j), and inserting subsection (j), and subsection (k), . (3) Effective date The amendments made by this subsection shall apply to amounts received in taxable years beginning after December 31, 2023. (d) Reporting requirements (1) In general Subpart B of part III of subchapter A of chapter 61, as amended by this Act, is