Special Bundle of 2 Webinars:

How IGSD Works, Why It's So Powerful and Popular, and Methods to Value the Receivable



Avatar
Avatar

Intergenerational Split Dollar Life Insurance in the Complex Estate Plan.




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

If you are not a LISI member please use the Buy Now Button below to pay the non-member price of $179 for this bundle of 2 webinars.

Registrant Email

After you pay you will be sent a link with the registration information. 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 $179 $159 for this bundle of 2 webinars.

Forgot Password?

To become a LISI member Click Here



Avatar
Avatar

Intergenerational Split Dollar Life Insurance in the Complex Estate Plan, Part 2: Valuing the Receivable




Recording and Slides are Available Here.



This webinar covers one of the most controversial valuation topics in tax practice today: how to value the receivable(s) held by the premium payers in intergenerational split-dollar life insurance arrangements.

Espen and Richard will discuss the background of these transactions and how this issue has become such a point of contention. Topics will include:

·The regulatory history

·The Morrissette case

·Common structures and provisions and how they impact valuations

·The difference between loan regime and economic benefit regime structures

·The main valuation inputs and techniques, including the discounted cash flow (DCF) method and The impact of life settlement transactions

·Examples of how the DCF method works will also be reviewed.

Note:There is no CE for this webinar



There will be no CE for this webinar



Leimberg Webinar Services





Avatar

Mark Merric

January 22, 2021 3:00PM ET - 4:30PM ET ET

Part 3: Mark Merric's Asset Protection Trilogy

More Info
Avatar

Steve Siegel

January 22, 2021 1:00PM ET - 2:30PM ET ET

Portability: An Estate Planning Game-Changer

More Info
Avatar Avatar

Alan Gassman and Brandon Ketron

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

PPP and EIDL Loan Rules Update and Review

More Info
Avatar

Bob Keebler

January 27, 2021 1:00 PM - 2:30 PM ET ET

How To Accurately Prepare the 2020 709 Gift Tax Return – Updated Class - Re-Broadcast

More Info
Avatar

Bobby Samuelson

January 28, 2021 3:00PM ET - 4:30PM ET ET

Making Sense of the Section 7702 Changes

More Info
Avatar Avatar Avatar

Martin Shenkman and Bob Keebler Jonathan Blattmachr

January 28, 2021 11:00P AM ET - 12:30 PM ET ET

Georgia Senate Election Results – Deep Dive PART 1 of 2 - Income Tax Planning - Rebroadcast

More Info
Avatar Avatar

Bob Keebler and Jere Doyle

January 28, 2021 1:00 PM ET - 2:30PM ET ET

REVIEW OF THE PROPOSED 2020 REGULATIONS REGARDING TRUST AND ESTATE DEDUCTIONS - A Special Re-Broadcast prior to the new regulations applying to 2020 returns. Master the new law prior to tax season

More Info
Avatar Avatar Avatar

Martin Shenkman and Bob Keebler Jonathan Blattmachr

January 29, 2021 11:00P AM ET - 12:30 PM ET ET

Georgia Senate Election Results – Deep Dive PART 2 of 2 - Estate Planning to do NOW! - Rebroadcast

More Info
Avatar

Eric Green

February 4, 2021 3:00 PM ET - 4:30PM ET ET

Criminal Tax for Accountants

More Info
Avatar Avatar Avatar

Martin Shenkman Steve Gorin Joy Matak

February 5, 2021 3:00PM ET - 4:30PM ET ET

2020 Gift Tax Returns: Practical Tips How to Report Common 2020 Transactions

More Info
Avatar

Tom Miller

February 5, 2021 1:00PM ET - 2:30PM ET ET

Why Most Executive Bonus Programs Fail—and How to Fix the Problem

More Info
Avatar

Eric Green

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

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

More Info
Avatar Avatar

Bruce Steiner Denise Appleby

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

Practical Applications of the SECURE Act and The CARES Act: How to Identify and Implement Strategies for 2021 and After

More Info
Avatar

Eric Green

February 26, 2021 1:00PM ET - 2:30PM ET ET

Resolving Back Tax Debts: Offers-in-Compromise, Installment Agreements, Uncollectable Status and Bankruptcy

More Info
Avatar

Mark Merric

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

Why Don’t I Understand Tax Provisions in An LLC Operating Agreement? Formation Concepts Part 1: Capital Accounts Compared to Stock

More Info
Avatar

Eric Green

March 5, 2021 3:00PM ET - 4:30PM ET ET

Tax Liens & Tax Levies

More Info
Avatar

Mark Merric

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

Why Don’t I Understand Tax Provisions in An LLC Operating Agreement? Formation Concepts Part 2: Capital Accounts Compared to Stock

More Info
Avatar

Mark Merric

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

Why Don’t I Understand Tax Provisions in An LLC Operating Agreement? Formation Concepts Part 3: Deducting Losses and Four Tax Hurdles

More Info