Avatar Avatar

Intergenerational Split Dollar Life Insurance in the Complex Estate Plan.



Watch Now!
Recording and Slides are Available Here


Alan Jensen and Brent Berselli - Intergenerational Split Dollar Life Insurance in the Complex Estate Plan.
Please join Alan Jensen and Brent Berselli in their 60 minute LISI webinar tilted "Intergenerational Split Dollar Life Insurance in the Complex Estate Plan." Intergenerational split dollar ("IGSD") arrangements are increasingly in the crosshairs of the IRS. In challenging such arrangements, the Service often takes a "kitchen sink" approach on audit and tax court litigation. Typical IRS challenges to invalidate the arrangement or limit its tax efficiency include:

(1) sham transaction, particularly if the arrangement lacks a substantial and apparent business purpose;
(2) step-transaction arguments pursuant to which the Service asserts that the IGSD amounts to a gift at inception; and
(3) valuation of the IGSD receivable included in the decedent's estate.

A favorable summary judgement ruling for the taxpayer in Morrissette v. United States alleviated one significant concern with respect to IGSD arrangements - a lump sum, single premium policy does not confer any benefit aside from current life insurance protection. Therefore, taxpayers may continue to avail themselves of the deemed ownership exception in the Treasury Regulations pursuant to which the donor is treated as the owner of the life insurance policies where the only benefit provided to the donee is current life insurance protection. Counsel structuring such arrangements, therefore, can have certainty that the structure will be governed by the economic benefit, rather than the loan, regime. Notwithstanding the taxpayer's initial victory, Morrissette remains in litigation. Messiers Jensen and Berselli will review the recent developments in Morrissette as well as provide insight into their experience litigating, and reaching a favorable settlement in, a similar case with the Service.
This presentation will also address:
· Overview and common uses of IGSD arrangements;
· Tax treatment (i.e. income, gift, estate) of structuring an IGSD arrangement under the economic benefit and loan regimes;
· Drafting tips to document the IGSD arrangement;
· Considerations in valuing the IGSD receivable in the decedent's estate; and
· Risks and traps to avoid in documenting an IGSD arrangement.
· And much more!




There will be no CE for this webinar


For those who have a conflict with the date/time, The session will be recorded. Simply register and you will have unlimited access to the recording.

Although they are scheduled for a particular time and date - once purchased - they can be viewed at ANY TIME!.

If you are not a LISI member please use the Buy Now Button below to pay the non-member price of $129*. *plus applicable sales tax (if any)

Registrant Email:

After you pay you will be sent a link with the registration information. Your webinar registration is designed for one individual user and groups up to 5 individuals. Sharing beyond this is not permitted. If you are interested in group access to our webinar content, please send an email to lisiwebinars@gmail.com

If you have any questions, please contact webinaradmin@leimbergservices.com

NOTE: To pay using a credit card, use the botton labeled
"Pay with Debit or Credit Card" after clicking the Buy Now button below.

If you are a LISI member, please login below to receive the member price of $99* for this webinar. *plus applicable sales tax (if any)

Forgot Password?

To become a LISI member Click Here

J. Alan Jensen is of counsel in Holland & Knight's Portland office. He focuses on tax planning for individuals and businesses, including corporate and estate planning for closely held and family-owned businesses. Mr. Jensen advises businesses and individuals with regard to the operation, expansion or transfer of their businesses. He also advises clients, agents and insurers about sophisticated applications of life insurance and activities in the life settlement market. Mr. Jensen was on the ABA liaison committee from 2001 to 2003 during the drafting of the Internal Revenue Service Regulations governing split dollar financing of life insurance premiums. He appears as an expert witness on tax controversies. Additionally, he counsels on wealth preservation, including the use of asset protection trusts. More. Brent Berselli is an associate in Holland & Knight's Portland office and is a member of the firm's Private Wealth Services Practice Group. Mr. Berselli focuses his practice on tax planning for individuals and businesses, including corporate and estate planning for closely held and family owned businesses. In addition, he provides tax planning counsel for all types of business transactions related to corporate entities, including IRC § 501(c)(3) nonprofit corporations, general and limited partnerships, subchapter C and subchapter S corporations, and limited liability companies. Mr. Berselli also represents personal representatives of probate estates, trustees, conservators and guardians in the discharge of their fiduciary duties More.


Avatar

Bob Keebler

March 9, 2021 3:00 PM ET - 4:30 PM ET ET

THE TAX ASPECTS OF DECANTING AND REFORMING TRUSTS

More Info
Avatar Avatar

Michael Geeraerts Jim Magner

March 10, 2021 11:00AM ET - 12:30PM ET ET

Alternative Life Insurance Ownership Structures if Congress Takes a Swing at ILITs Using New Code Section 2901 - A Special Re-Broadcast

More Info
Avatar Avatar

Alan Gassman and Brandon Ketron

March 10, 2021 1:00PM ET - 2:30PM ET ET

PPP and Employee Retention Credit (ERC) Update - What's New and What's Still to Come!

More Info
Avatar

Paul Hood

March 11, 2021 1:00PM ET - 2:30PM ET ET

Part 4 of Paul Hood's Six-Part Series on the Federal Transfer Tax System: Estate Tax Credits; Estate Tax Reimbursement & Apportionment Provisions, Gift Tax Introduction & Overview of Generation-Skipping Transfer Tax

More Info
Avatar

Linas Sudzius

March 11, 2021 3:00PM ET - 4:30PM ET

How to Handle an Unexpected Form 1099-R Received from a Life Insurance Company/Financial Institution: Reconciling with all the Tax Partners

More Info
Avatar

Bob Keebler

March 11, 2021 11:00 AM ET 12:30 PM ET

IRAs Payable to Trusts After the Secure Act – 2021 Estate Planning Edition

More Info
Avatar

Steve Siegel

March 12, 2021 1:00PM ET - 2:30PM ET

The Complete Trust Course: Part 2

More Info
Avatar

Bob Keebler

March 12, 2021 3:00PM ET - 4:30PM ET

THE AMERICAN RESCUE PLAN ACT of 2021: What the Sophisticated Advisor Needs to Know Now!

More Info
Avatar

Bob Keebler

March 15, 2021 3:00PM ET - 4:30PM ET ET

THE AMERICAN RESCUE PLAN ACT of 2021: What the Sophisticated Advisor Needs to Know Now!

More Info
Avatar

Bob Keebler

March 15, 2021 6:00PM ET - 7:30PM ET ET

THE AMERICAN RESCUE PLAN ACT of 2021: What the Sophisticated Advisor Needs to Know Now!

More Info
Avatar

Bob Keebler

March 16, 2021 3:00PM ET - 4:30PM ET ET

Tactical and Strategic Roth Conversions in 2021

More Info
Avatar

Linas Sudzius

March 18, 2021 3:00PM ET - 4:30PM ET ET

Private Letter Ruling 202031008 Opens Multiple Annuity Planning Opportunities

More Info
Avatar

Paul Hood

March 18, 2021 1:00PM ET - 2:30PM ET ET

Part 5 of Paul Hood's Six-Part Series on the Federal Transfer Tax System: Selected Gift Tax Topics; Overview of Generation-Skipping Transfer Tax

More Info
Avatar Avatar

Michael Liebeskind Bryan Bloom

March 19, 2021 3:00PM ET - 4:30PM ET ET

Private Placement Life Insurance (PPLI) and Private Placement Annuities (PPA) - A Major Tax Planning Opportunity for HNW Clients in 2021

More Info
Avatar

Paul Hood

March 19, 2021 1:00PM ET - 2:30PM ET ET

Out of the Hood: Analysis With An Attitude©: Overview of Estate Planning From 30,000 Feet

More Info
Avatar

Steve Siegel

March 19, 2021 1:00PM ET - 2:30PM ET ET

The Complete Trust Course: Part 3

More Info
Avatar

Bob Keebler

March 23, 2021 3:00PM ET - 4:30PM ET ET

Tactical and Strategic Roth Conversions in 2021 - A Special Re-Broadcast

More Info
Avatar

Eric Green

March 25, 2021 1:00PM ET - 2:30PM ET ET

The Biggest Mistakes Made During Tax Season that Trigger IRS Enforcement!

More Info
Avatar

Paul Hood

March 25, 2021 1:00PM ET - 2:30PM ET ET

Part 6 of Paul Hood's Six-Part Series on the Federal Transfer Tax System: Valuation: General Principles

More Info
Avatar

Mark Merric

March 26, 2021 3:00PM ET - 4:30PM ET ET

Understanding Tax Provisions in An LLC Operating Agreement - Formation Concepts Part 2: Capital Accounts Compared to Stock

More Info
Avatar

Paul Hood

April 01, 2021 1:00PM ET - 2:30PM ET ET

Family Business Succession Planning-It’s a Contact Sport!!!

More Info
Avatar

Steve Oshins

April 02, 2021 1:00PM ET - 2:30PM ET ET

The Spousal Lifetime Access Trust: A Gifting and Creditor Protection Technique, What Advisors Need To Know for 2021

More Info
Avatar

Mark Haranzo

April 02, 2021 3:00PM ET - 4:30PM ET ET

Cross Border Prenuptial Agreements: Navigating the Dangerous Shoals of Love, Wealth and Marriage Involving Multiple Countries of Origin, Domicile and Residence

More Info
Avatar

Mark Merric

April 23, 2021 3:00PM ET - 4:30PM ET ET

Understanding Tax Provisions in An LLC Operating Agreement - Formation Concepts Part 3: Deducting Losses and Four Tax Hurdles

More Info