Much Ado About NothingMuch Ado About Nothing
On May 8, 2003, the Internal Revenue Service issued proposed regulations (Reg-164754-01) dealing with the valuation and taxation of benefits that a non-owner receives under an endorsement economic benefit regime equity split dollar arrangement. These proposed rules provide guidance on the tax implications of arrangements most people have never seen, are not likely to see and wouldn't want to replicate.
June 1, 2003
Charles L. Ratner
On May 8, 2003, the Internal Revenue Service issued proposed regulations (Reg-164754-01) dealing with the valuation and taxation of benefits that a non-owner receives under an endorsement economic benefit regime equity split dollar arrangement. These proposed rules provide guidance on the tax implications of arrangements most people have never seen, are not likely to see and wouldn't want to replicate.
The arrangement they address is one where the owner of the policy would not only permit the non-owner to designate by policy endorsement a personal beneficiary for a portion of the death benefit but also to have an interest in the policy cash value (or equity) disproportionate to the employee's share of the premium. The 200...
Unlock All Access Premium Subscription
Get Trusts & Estates articles, digital editions, and an optional print subscription. Choose your subscription now and dive into expert insights today!
Already Subscribed?
