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Intergenerational Split Dollar Life Insurance in the Complex Estate Plan.



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Alan Jensen and Brent Berselli - Intergenerational Split Dollar Life Insurance in the Complex Estate Plan.
Please join Alan Jensen and Brent Berselli in their 60 minute LISI webinar tilted "Intergenerational Split Dollar Life Insurance in the Complex Estate Plan." Intergenerational split dollar ("IGSD") arrangements are increasingly in the crosshairs of the IRS. In challenging such arrangements, the Service often takes a "kitchen sink" approach on audit and tax court litigation. Typical IRS challenges to invalidate the arrangement or limit its tax efficiency include:

(1) sham transaction, particularly if the arrangement lacks a substantial and apparent business purpose;
(2) step-transaction arguments pursuant to which the Service asserts that the IGSD amounts to a gift at inception; and
(3) valuation of the IGSD receivable included in the decedent's estate.

A favorable summary judgement ruling for the taxpayer in Morrissette v. United States alleviated one significant concern with respect to IGSD arrangements - a lump sum, single premium policy does not confer any benefit aside from current life insurance protection. Therefore, taxpayers may continue to avail themselves of the deemed ownership exception in the Treasury Regulations pursuant to which the donor is treated as the owner of the life insurance policies where the only benefit provided to the donee is current life insurance protection. Counsel structuring such arrangements, therefore, can have certainty that the structure will be governed by the economic benefit, rather than the loan, regime. Notwithstanding the taxpayer's initial victory, Morrissette remains in litigation. Messiers Jensen and Berselli will review the recent developments in Morrissette as well as provide insight into their experience litigating, and reaching a favorable settlement in, a similar case with the Service.
This presentation will also address:
· Overview and common uses of IGSD arrangements;
· Tax treatment (i.e. income, gift, estate) of structuring an IGSD arrangement under the economic benefit and loan regimes;
· Drafting tips to document the IGSD arrangement;
· Considerations in valuing the IGSD receivable in the decedent's estate; and
· Risks and traps to avoid in documenting an IGSD arrangement.
· And much more!




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J. Alan Jensen is of counsel in Holland & Knight's Portland office. He focuses on tax planning for individuals and businesses, including corporate and estate planning for closely held and family-owned businesses. Mr. Jensen advises businesses and individuals with regard to the operation, expansion or transfer of their businesses. He also advises clients, agents and insurers about sophisticated applications of life insurance and activities in the life settlement market. Mr. Jensen was on the ABA liaison committee from 2001 to 2003 during the drafting of the Internal Revenue Service Regulations governing split dollar financing of life insurance premiums. He appears as an expert witness on tax controversies. Additionally, he counsels on wealth preservation, including the use of asset protection trusts. More. 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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