SPLIT-DOLLAR OPPORTUNITIESSPLIT-DOLLAR OPPORTUNITIES
Although the Treasury Department and the Internal Revenue Service have significantly diminished its income tax advantages, split-dollar insurance can still be a valuable estate-planning tool. The IRS's final regulations1 created the ability to use coordinated strategies to fund life insurance premiums without making any taxable gifts or, in some cases, triggering the generation-skipping transfer (GST)
May 1, 2006
Richard L. Harris, managing member, BPN Montaigne LLC, Clifton, NJ
Although the Treasury Department and the Internal Revenue Service have significantly diminished its income tax advantages, split-dollar insurance can still be a valuable estate-planning tool. The IRS's final regulations1 created the ability to use coordinated strategies to fund life insurance premiums without making any taxable gifts or, in some cases, triggering the generation-skipping transfer (GST) tax. Artful use of these strategies can result in substantial savings in the tax cost of buying new policies. They also can help remedy situations in which clients have existing split-dollar arrangements that need significant gift tax dollars to fix.
Be warned, though, structu...
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