For estate planning using life insurance, and especially for large premium cases, split dollar offers an attractive method for funding the premiums with favorable gifting consequences. Before 2003, the rules for split dollar were a collection of revenue rulings and private letter rulings. But, beginning with Notice 2001-10 and concluding with published Treasury Regulations Sections 1.61-22 and 1.7872-15 and Revenue Ruling 2003-105, the Treasury and the Internal Revenue Service changed the ...

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