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A New Split-Dollar ImperativeA New Split-Dollar Imperative
Ever since the Internal Revenue Service issued Notice 2001-101 in January of 2001, planners who advise clients on their split-dollar life insurance arrangements have had to deal with a Byzantine set of rules that yield different answers depending on the type of arrangement, when it was implemented, and if amended (also when). With the passage of Internal Revenue Code Section 409A and the issuance
Charles L. Ratner & Lawrence Brody & Mary Ann Mancini
Ever since the Internal Revenue Service issued Notice 2001-101 in January of 2001, planners who advise clients on their split-dollar life insurance arrangements have had to deal with a Byzantine set of rules that yield different answers depending on the type of arrangement, when it was implemented, and if amended (also when). With the passage of Internal Revenue Code Section 409A and the issuance of Notice 2007-34,2 planners have to deal with a whole new set of additional complications.
Notice 2007-34, issued April 10, 2007, accompanied publication of the final Section 409A regulations. The notice provides guidance on the application of Section 409A3 to employment-related split-dollar l...
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