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Planning with Intergenerational Split-Dollar After Cahill and Morrissette

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The Tax Court’s recent opinion in Estate of Cahill v. Commissioner and an order in Estate of Morrissette v. Commissioner strongly suggest that the Court will reject a low estate tax value for a decedent's interest in a typical intergenerational split-dollar life insurance arrangement.  In their exclusive LISI Webinar, Howard Zaritsky and Brent Berselli will review the Court's analysis and discuss how to modify the structure and operation of an intergenerational split-dollar arrangement to mitigate the problems raised in these cases. Here is just some of what Howard and Brent will cover:

  • INTRODUCTION: Brief description of intergenerational split-dollar life insurance arrangements and what they are intended to achieve.
  • INCOME AND GIFT TAX TREATMENT AND ESTATE OF MORRISSETTE: Discuss Morrissette and the income and gift tax advantages of the economic benefit regime.  
  • ESTATE TAX TREATMENT AND ESTATE OF CAHILL AND ESTATE OF MORRISSETTE II: Discuss Cahill and the application of Sections 2036, 2038, and 2703. Discuss order in Morrissette. 

       o   Better Facts Would Help

       o   A Competent Donor

       o   A Business Purpose

       o   An Independent Trustee

       o   No Third-Party Loan

       o   What if the Agreement Does Not Permit Termination At All?

       o   Effect of Having the Agreement not Permit Termination or be silent as to termination?

       o   Effect of Using a Loan Repayable at the Insured’s Death and Bearing Long-Term AFR Interest     

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Howard M. Zaritsky, J.D., LL.M. (Tax) www.howardzaritsky.com Howard M. Zaritsky is a attorney and a retired partner in the firm of Zaritsky & Zaritsky, in Fairfax, Virginia, where his practice was limited to estate planning and administration and related tax matters. He has been a lecturer at most major tax and estate planning institutes, including the University of Miami (Heckerling) Estate Planning Institute, where he is a member of the advisory committee. He is the author or co-author of numerous articles and treatises, including: Tax Planning for Family Wealth Transfers During Life and Tax Planning for Family Wealth Transfers at Death both published by Thomson-Reuters/WG&L. He is a Fellow of the American College of Trust and Estate Counsel and the American College of Tax Counsel, a member of the Virginia State Bar, and former Chair of the Virginia Bar Association Section on Wills, Trusts & Estates. Mr. Zaritsky lives on a farm with his wife and several groundhogs, near the thriving metropolis of Rapidan, Virginia.
Brent Berselli is an associate in Holland & Knight's Portland office and is a member of the firm's Private Wealth Services Practice Group. Mr. Berselli focuses his practice on tax planning for individuals and businesses, including corporate and estate planning for closely held and family owned businesses. In addition, he provides tax planning counsel for all types of business transactions related to corporate entities, including IRC § 501(c)(3) nonprofit corporations, general and limited partnerships, subchapter C and subchapter S corporations, and limited liability companies. Mr. Berselli also represents personal representatives of probate estates, trustees, conservators and guardians in the discharge of their fiduciary duties More.


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