Avatar Avatar

Is Split-Dollar the Answer for College Coaches Looking to Sack the IRC 4960 Excise Tax?: What Advisors Need to Know about the New Penalty Tax to Better Counsel Clients



Watch Now!
Recording and Slides are Available Here .


The Tax Cuts and Jobs Act added IRC § 4960 which imposes an excise tax on tax-exempt organizations equal to the corporate tax rate (21%) on compensation over $1 million paid to its five highest-paid employees.  College coaches and athletic directors are often the highest paid employees on campus, as was highlighted in 2016 with Jim Harbaugh’s $5 million contract extension with the University of Michigan.  

Harbaugh and the University entered into a loan-regime split-dollar agreement, requiring the University to loan millions of dollars for the payment of Harbaugh’s life insurance premiums.  It seems that split-dollar loans would avoid the new § 4960 excise tax, so these arrangements could become more prevalent with highly compensated college coaches and their employers. 

While the University of Michigan and Jim Harbaugh may have had a crystal ball when structuring their split-dollar agreement a few years ago, tax-exempts that could be subject to the new excise tax will have to get creative in how they compensate their top employees. In their exclusive LISI webinar, Michael Geeraerts and Jim Magner will review how the excise tax works and will examine a number of creative planning strategies that may lessen its impact. 

Topics they will cover include:

·      Which tax-exempt organizations have potential exposure;

·      Important definitional tests such as “covered employees” “remuneration” the “related party” rule and “parachute payments;”

·      A survey of compensation paid to coaches and athletic directors;

·      A review of the disclosure requirements on Form 990 and the Schedule J;

·      How split dollar arrangements and third-party compensation can avoid the excise tax;

·      Q&A



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.

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 $99 for this webinar.

Forgot Password?

To become a LISI member Click Here

Michael Geeraerts, CPA, JD, CGMA®, CLU® is an advanced planning consultant at The Guardian Life Insurance Company of America®. Prior to joining Guardian, Michael was a manager at PricewaterhouseCoopers LLP and a tax consultant at KPMG LLP. Michael’s experiences range from preparing tax returns for middle market companies, auditing billion-dollar mutual funds’ financial statements, to researching unique tax savings strategies for various companies.  Michael has written articles for numerous national publications and has delivered continuing education courses to CPAs and attorneys on a variety of estate, business and income tax planning strategies.



Jim Magner is an advanced planning attorney at The Guardian Life Insurance Company of America®.  Prior to joining Guardian, Jim was General Counsel for a national broker dealer/brokerage general agency.  Jim previously worked as an Attorney-Advisor in the IRS’s Office of Chief Counsel, in Washington, DC.  While with the Office of Chief Counsel, Jim wrote private and public rulings on estate, gift, GST and charitable remainder trust issues. 


Avatar

Paul Hood

November 15, 2018 4:00 PM EDT - 5:30 PM ET ET

Structuring Defined Value Clauses in Trust Transfers: Formula Allocations and Price Adjustment Clauses:

More Info
Avatar

Bob Keebler

November 15, 2018 2:00 PM EDT - 3:30 PM EDT ET

199A and Specified Service Businesses

More Info
Avatar

Alan Gassman

November 16, 2018 3:00 PM EDT - 4:30 PM EDT ET

Dynamic Planning Strategies for the Well Informed Advisor

More Info
Avatar Avatar

Bob Keebler and Michael Geeraerts

November 29, 2018 1:00 PM EDT - 2:30 PM ET ET

199A Planning Strategies & 2018 Return Preparation: What Advisers Have to Know Before Year-End

More Info
Avatar

Paul Hood

November 29, 2018 3:00 PM EDT 4:30 PM EDT

Tour of Estate/Charitable Planning Tools & Techniques-From Meat & Potatoes To Cutting Edge

More Info
Avatar

Bob Keebler

November 30, 2018 1:00 PM EDT - 2:30 PM EDT

Do's and Don'ts of 199A Planning

More Info
Avatar

Chuck Rubin

November 30, 2018 3:00 PM ET - 4:30 PM EDT

Florida Homestead Law Made Easy – Well, At Least Easier

More Info
Avatar

Bob Keebler

December 06, 2018 1:00 PM EDT - 2:30 PM EDT

An Estate and Income Tax Planning Perspective on the Tax Cuts and Jobs Act, a Special 2-for-1 Offer

More Info
Avatar

Paul Hood

December 6, 2018 3:00 PM EDT 4:30 PM EDT ET

Planning for the Surviving Spouse

More Info
Avatar Avatar

Alan Gassman, Chris Denicolo

December 7, 2018 3:00 PM EDT - 4:30 PM EDT ET

10 Biggest IRA-Trust Mistakes

More Info
Avatar

James P. Weller, JD, LL.M

December 13, 2018 3:00 PM EDT - 4:30 PM EDT ET

A Deep Dive into the Proposed Regulations for Qualified Opportunity Funds: What Surfaced and What Didn’t

More Info
Avatar

Bob Keebler

December 14, 2018 3:00 PM EDT - 4:30 PM EDT ET

Year-End Proactive Planning Ideas

More Info
Avatar

Bob Keebler

December 20, 2018 3:00 PM EDT - 4:30 PM EDT ET

Choice of Entity Planning

More Info
Avatar

Bob Keebler

December 21, 2018 3:00 PM EDT - 4:30 PM EDT ET

Tax Planning for Seliing a Business

More Info
Avatar

Mike Jones

January 4, 2019 3:00 PM EDT - 4:30 PM ET ET

Significant Recent Estate, Gift and Generation-Skipping Transfer Tax Developments Affecting Estate Planning and Administration

More Info