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Private Split-dollar ArrangementsPrivate Split-dollar Arrangements
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
Lawrence Brody & Richard L. Harris
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 landscape for split-dollar arrangements. The regulations ended “equity” split-dollar arrangements as of Sept. 17, 2003 (that is, those that allowed for the supposed tax-free transfer of cash value from the premium-payor...
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