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Today's Split DollarToday's Split Dollar
The final split-dollar regulations that were effective as of Sept. 17, 2003 (T.D. 9092) became the operative guidance for arrangements that either were implemented after this date or that existed before Sept. 17, 2003 but were materially modified thereafter.1 Despite the complexity of these regulations, clients still can use split dollar to efficiently finance the premiums for substantial amounts
Lawrence Brody, partner, Bryan Cave LLP, St. Louis, and Charles L. Ratner, national director of p
The final split-dollar regulations that were effective as of Sept. 17, 2003 (T.D. 9092) became the operative guidance for arrangements that either were implemented after this date or that existed before Sept. 17, 2003 but were materially modified thereafter.1 Despite the complexity of these regulations, clients still can use split dollar to efficiently finance the premiums for substantial amounts of life insurance.
In our scenario, we will assume the client will use an irrevocable life insurance trust (ILIT) to own the policy to keep the proceeds of the policy out of his estate. We also will assume that the client is the majority owner and emp...
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