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Final Regs Released 10/25: Major Changes to Transfer for Value Rule! - TD 9879



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2017 tax reform attacked sales on the life insurance settlement market.  Such sales and similar transactions are “reportable policy sales.”  Generally, when a policy has been transferred in such a sale, its death benefits will be subjected to income tax.  When issuing guidance on reportable policy sales, the Treasury and the IRS decided to overhaul the regulations governing the transfer for value rule.  Thus, these regulations are the most important guidance on the income taxation of life insurance since the split-dollar regulations were issued.

If you'd like to learn more about this important topic, then consider joining Steve Gorin in his exclusive LISI Webinar where he will cover the final transfer for value regulations. Here's just a few of the things Steve will cover in his content-filled, 90-minute webinar: 

·         When a policy transfer, which is not a reportable policy sale, will subject to income tax part or all of the death benefit.

·         When a transfer is a reportable policy sale, including a detailed look at which transferees are targeted by these rules.

·         Whether a transfer for value can be cleansed.

·         Although buy-sell agreements for an operating business generally will not trigger the transfer for value rules, when life insurance relating to such agreements may become tainted for other reasons so that death benefits become income taxable.

·         How to try to minimize income tax risks in using life insurance to fund a buy-sell agreement.




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Steve is a nationally recognized practitioner in the areas of estate planning and the structuring of privately held businesses. Lawyers, accountants and business owners regularly look to Steve for fresh, highly knowledgeable insights into the best possible tax and estate planning approaches to their transactions.

Steve crafts estate plans for individuals, keeping in mind their financial security and desire to save income and estate tax. In his work for businesses, Steve helps owners plan for the eventual sale (to co-owners, employees, or third parties)or transfer (to family members), and provides a legal framework for an orderly transition while strategically saving income, transfer, and FICA taxes.

Drawing on his background as an accountant — and his still-current CPA license and Chartered Global Management Accountant credential — Steve structures businesses to achieve business objectives and save income or estate tax. He has helped fledgling businesses organize, thriving businesses restructure to save hundreds of thousands of dollars of income tax when planning a transition to the next ownership group, and mature multi-million or billion-dollar businesses plan tax-saving transfers to the next generation.

Over the course of his 30-year career, Steve has amassed a deep knowledge of nearly every aspect of tax strategy for privately held businesses and freely shares that knowledge with others in the field. His quarterly newsletter, Business Succession Solutions," is considered essential reading for hundreds of CPAs and attorneys, who describe it as "a fantastic contribution to the field." Steve also maintains a blog, Business Succession Solutions, intended to help business owners — and those who advise or support them — consider smart tax strategies.

Steve is a highly visible member of the ABA's Real Property, Trust & Estate Law Section and the American College of Trust & Estate Counsel, which regularly directs its members to Steve's quarterly newsletter. He has represented both groups in comments to the IRS, the U.S. Treasury, and tax lawmakers.


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