We will discuss what can be done to “fix” these old equity collateral
assignment arrangements, including:

• Taxation of these arrangements under Notice 2002-8

• What its “no inference” provision may mean and our ability to rely on it, both during the term
of the arrangement and on its termination during the insured’s lifetime.

• The impact of Neff vs. Comm.

• The potential application of Section 409A to employment related split-dollar arrangements
including Notice 2007-34

• Its grandfathering provisions

• Economic benefit arrangements not grandfathered from Section 409A

• The absence of any “no inference” language

• The requirement for amending those arrangements by 2008 and dealing with those which weren’t

• Enter the fix it shop

There will be no CE for this webinar


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