Special Bundle of 2 Webinars:
Split Dollar Series Parts 2 and 3.
Part 2 Split Dollar Webinar Series. : Using Post-Final Regulation Economic Benefit Regime Split-Dollar Arrangements
Recording and Slides are Available Here.
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Click here to see the Bundle of all 3 Split Dollar Webinars
Click here to see the Bundle of parts 2 and 3
Using Post-Final Regulation Economic Benefit Regime Split-Dollar
Arrangements.
• 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
Rates
- Survivorship policy rates
• Taxation of policy equity under the Final Regulations
- With one exception, these rules are
prospective
- 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
assignment arrangements
There will be no CE for this webinar
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Part 3 Split Dollar Webinar Series. ::Using Post-Final Regulation Loan Regime Arrangements
Recording and Slides are Available Here.
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Click here to see the Bundle of all 3 Split Dollar Webinars
Click here to see the Bundle of parts 2 and 3
• Loans that bear interest at the AFR and those that don’t
- Loans that bear interest at the AFR requiring interest payments or interest accrued
- Loans that don’t bear interest at the AFR
• The possible application of Federal Reserve Regulation U to large loan regime arrangements
• Exit strategies
• Related party loan regime arrangements respected as bona fide debt obligations
• Loan regime formats
• The insured as the lender
• The insured’s spouse as the lender
• The insured’s employer or controlled entity is the lender
There will be no CE for this webinar
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