Part 2 Split Dollar Webinar Series. : Using Post-Final Regulation Economic Benefit Regime Split-Dollar Arrangements
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Using Post-Final Regulation Economic Benefit Regime Split-Dollar
• There have always been two tax issues in economic benefit split-dollar arrangements
- The measure of the economic benefit
- The treatment of policy equity
• Measure of the economic benefit
- It is premium insensitive
- Measured by the lower of the carrier’s qualifying term rates under Notice 2002-8 or the IRS Table
- Survivorship policy rates
• Taxation of policy equity under the Final Regulations
- With one exception, these rules are
- The exception is for “material modifications”
• Under the Final Regulations, which regime – loan or economic benefit – apply depends
exclusively on policy ownership
- The one exception is non-equity donor/donee or employer/employee collateral
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