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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