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Part 1 of 3 Part SPLIT-DOLLAR WEBINAR SERIES:
THE SPLIT-DOLLAR “FIX IT” SHOP – WHAT TO DO WITH PRE-FINAL REGULATION SPLIT-DOLLAR ARRANGEMENTS



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Recording and Slides are Available Here


We will discuss what can be done to “fix” these old equity collateral
assignment arrangements, including:

• Taxation of these arrangements under Notice 2002-8

• What its “no inference” provision may mean and our ability to rely on it, both during the term
of the arrangement and on its termination during the insured’s lifetime.

• The impact of Neff vs. Comm.

• The potential application of Section 409A to employment related split-dollar arrangements
including Notice 2007-34

• Its grandfathering provisions

• Economic benefit arrangements not grandfathered from Section 409A

• The absence of any “no inference” language

• The requirement for amending those arrangements by 2008 and dealing with those which weren’t

• Enter the fix it shop



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Lawrence Brody is a Partner of Bryan Cave LLP, an international law firm, resident in the St. Louis office. He is a member of its Private Client Service Group and its Technology, Entrepreneurial & Commercial Practice Client Service Group. He has been an Adjunct Professor at Washington University School of Law since 1968, teaching Estate Planning and Drafting, a visiting Adjunct Professor at the University of Miami Law School, teaching a course on Life Insurance, and is the author or co-author of numerous articles and books on the use of life insurance in estate and employee benefit planning, including two BNA Tax Management Portfolios, two books for the National Underwriter Company, and a number of volumes in the ABA Insurance Counselor Series.


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