Do you think that split-dollar arrangements (other than premium loans under the split-dollar loan regime) faded away when the Internal Revenue Service tightened the rules on them in the final regulations issued Sept. 17, 2003?1 Think again. New variations of the split-dollar technique keep appearing. Discount private split-dollar — also known as “three-generation split-dollar” — is one of the popular new techniques. Promoted around the country in recent years, it involves a private ...

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