Special Bundle of 13 Webinars:
A Comprehensive Review of Important Life Insurance Funded Planning Techniques
A Comprehensive Review of Important Life Insurance Funded Planning Techniques
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Intergenerational Split Dollar Life Insurance in the Complex Estate Plan.
Recording and Slides are Available Here.
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!
There will be no CE for this webinar
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Private Placement Life Insurance & Annuity Strategies for Wealthy Families: What the Sophisticated Advisor Needs to Know
Recording and Slides are Available Here.
Please join Eric Naison-Phillips for a 60-minute LISI webinar titled Private Placement Life Insurance & Annuity Strategies for Wealthy Families: Trends, Challenges, and Strategies for Growth in the Private Placement Industry.” Gaining traction as a top investment vehicle for tax-efficient planning among ultra-affluent clients, private placement life insurance and annuities are increasingly a topic of conversation among investors and advisors alike.
There will be no CE for this webinar
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Intergenerational Split Dollar Life Insurance in the Complex Estate Plan, Part 2: Valuing the Receivable
Recording and Slides are Available Here.
This webinar covers one of the most controversial valuation topics in tax practice today: how to value the receivable(s) held by the premium payers in intergenerational split-dollar life insurance arrangements.
Espen and Richard will discuss the background of these transactions and how this issue has become such a point of contention. Topics will include:
·The regulatory history
·The Morrissette case
·Common structures and provisions and how they impact valuations
·The difference between loan regime and economic benefit regime structures
·The main valuation inputs and techniques, including the discounted cash flow (DCF) method and The impact of life settlement transactions
·Examples of how the DCF method works will also be reviewed.
Note:There is no CE for this webinar
There will be no CE for this webinar
Top Insurance Planning Mistakes and How to Fix Them, Part 1
Recording and Slides are Available Here.
Life insurance is a powerful and commonly used tool in both estate planning and employee benefits planning, and its flexibility can help clients achieve a number of important objectives. Obtaining the expected results often requires complying with specific, sometimes complex and confusing requirements. During his webinar, Larry will discuss how to avoid 25 common mistakes and how to fix them when they occur. Topics covered will include:
·Personal or estate planning transactions
·Business and employee benefit transactions
·Business and employee benefit transactions with estate planning implications
Note:There will be no CE for this webinar
There will be no CE for this webinar
Life insurance is a powerful and commonly used tool in both estate planning and employee benefits planning, and its flexibility can help clients achieve a number of important objectives. Obtaining the expected results often requires complying with specific, sometimes complex and confusing requirements. During his webinar, Larry will discuss how to avoid 25 common mistakes and how to fix them when they occur. Topics covered will include:
·Personal or estate planning transactions
·Business and employee benefit transactions
·Business and employee benefit transactions with estate planning implications
Note:There will be no CE for this webinar
Top Insurance Planning Mistakes and How to Fix Them, Part 2
Recording and Slides are Available Here.
Life insurance is a powerful and commonly used tool in both estate planning and employee benefits planning, and its flexibility can help clients achieve a number of important objectives. Obtaining the expected results often requires complying with specific, sometimes complex and confusing requirements. During his webinar, Larry will discuss how to avoid common mistakes and how to fix them when they occur. Topics covered will include:
·Personal or estate planning transactions
·Business and employee benefit transactions
·Business and employee benefit transactions with estate planning implications
There will be no CE for this webinar
The Federal Income Tax Treatment of Life Insurance Policies - Click to Listen to Larry's description
Recording and Slides are Available Here.
This webinar will discuss and analyze a variety of Federal income taxation relating to the ownership of and transactions with life insurance policies, including
- The definitions of life insurance
- Modified endowment contracts
- The taxation of policy dividends
- Loans, withdrawals
- Surrenders or lapses
- Policy sales
- The taxation of life insurance death benefits
- Non-taxable exchanges of policies.
There will be no CE for this webinar
- The definitions of life insurance
- Modified endowment contracts
- The taxation of policy dividends
- Loans, withdrawals
- Surrenders or lapses
- Policy sales
- The taxation of life insurance death benefits
- Non-taxable exchanges of policies.
What Is the Fair Market Value of a Policy for Federal Tax Purposes and How Do We Determine It? - Click to Listen to Larry's description
Recording and Slides are Available Here.
This webinar will try to answer the question of what the “fair market value” of a life insurance policy is for Federal tax purposes, both for Federal income tax purposes (when policies are transferred as compensation or as distributions from qualified retirement plans) and for Federal gift tax purposes (when policies are transferred by gift or in sales to family members or trusts for their benefit).
In determining a policy’s fair market value for income tax purposes, the webinar will focus on the safe harbors provided by the IRS for policies transferred out of qualified retirement plans and whether those safe harbors apply to other Federal income tax transactions; in determining the value of a policy for Federal gift tax purposes, the webinar will focus on the valuation conventions provided for in the IRS Regulations, the use of appraisers, reliance on Form 712 values, and full value sales of policies under Section 2035
There will be no CE for this webinar
Taxation of Real Estate After Tax Reform - Click to Listen to Bob's description
Recording and Slides are Available Here.
Tax reform has produced great opportunities for clients with real estate, but, there are also traps to watch out for. Estate or tax planning attorneys, CPAs and financial advisors will benefit by joining us for “Tax Planning for Real Estate Under the Tax Reform Bill” a presentation by Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished), CGMA.
Bob will be covering the following:
• Discover how to freeze values and retain the opportunity for a step-up
• Acquire an understanding of cost segregation studies the many benefits and the potential adverse impact under the tax reform bill
• Important estate and income tax planning strategies for investors and real estate developers
• Understand the impact on the NIIT
• Treatment of Trusts owns real estate and the potential use of NINGs and other non-grantor trusts
• Understand the 20% small business deduction including testing on an entity-by-entity basis
• Understand the 30% interest limitation and the adverse impact of entity-by-entity basis
• Review of the statutory construction of the 20% small business deduction with an emphasis on real estate
• Understand the adverse impact of electing out of the interest limitation and being forced to use ADS depreciation and lose bonus depreciation
• Discover why deleveraging certain entities and increasing debt on others may increase your 20% deduction and reduce your effective tax rate
• Many easy to understand examples of the 20% and 30% tests, along with bonus depreciation and Section 179 Deductions
• Traps for lawyers, CPAs and planners doing asset protection and estate planning with multiple entities
• Create estate plans for real estate investors while protecting the income tax benefits
• Learn about the loss limitations under Sections 461, 465 and 469
• Understand “unadjusted” basis including the trap under the 10 year rule
• Discover why Section 754 takes an increased importance
• Discover how to compute the 2.5% of assets test including the adverse impact of Section 179 Deductions
• Plus a great deal more!
There will be no CE for this webinar
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
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
There will be no CE for this webinar
Part 2 Split Dollar Webinar Series. : Using Post-Final Regulation Economic Benefit Regime Split-Dollar Arrangements
Recording and Slides are Available Here.
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Using Post-Final Regulation Economic Benefit Regime Split-Dollar
Arrangements.
• There have always been two tax issues in economic benefit split-dollar arrangements
- The measure of the economic benefit
- The treatment of policy equity
• Measure of the economic benefit
- It is premium insensitive
- Measured by the lower of the carrier’s qualifying term rates under Notice 2002-8 or the IRS Table
Rates
- Survivorship policy rates
• Taxation of policy equity under the Final Regulations
- With one exception, these rules are
prospective
- The exception is for “material modifications”
• Under the Final Regulations, which regime – loan or economic benefit – apply depends
exclusively on policy ownership
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The one exception is non-equity donor/donee or employer/employee collateral
assignment arrangements
There will be no CE for this webinar
Part 3 Split Dollar Webinar Series. ::Using Post-Final Regulation Loan Regime Arrangements
Recording and Slides are Available Here.
Save a bundle with a bundle.
Click here to see the Bundle of all 3 Split Dollar Webinars
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• Loans that bear interest at the AFR and those that don’t
- Loans that bear interest at the AFR requiring interest payments or interest accrued
- Loans that don’t bear interest at the AFR
• The possible application of Federal Reserve Regulation U to large loan regime arrangements
• Exit strategies
• Related party loan regime arrangements respected as bona fide debt obligations
• Loan regime formats
• The insured as the lender
• The insured’s spouse as the lender
• The insured’s employer or controlled entity is the lender
There will be no CE for this webinar
Inside Private Placement and the IDF Landscape: Sophisticated Planning to Optimize Net After-Tax Results
Recording and Slides are Available Here.
In this 60-minute LISI webinar, Winged Keel Principal Eric Naison-Phillips will provide an inside look at the growing appeal of Private Placement Annuity and Life Insurance products, a real-time update on the evolution of the Insurance-Dedicated Fund (IDF) landscape, and sophisticated planning applications for Private Placement Life Insurance and Annuities. This webinar will cover the following topics:
Applications
· Accumulation of investment returns on a tax-deferred basis
· Ability to reallocate assets amongst IDF investment options without tax
· Elimination of K-1s to end investors
· Potential elimination of income taxes at the end of the insured’s life
· Institutional PPLI: Providing a means to offset balance sheet liabilities associated with deferred compensation plans
· Group Variable Annuity: Eliminate or reduce (i) Unrelated Business Taxable Income for U.S. Tax-Exempt investors and
(ii) Effectively Connected Income Foreign Investment in Real Property Tax Act (“FIRPTA”) taxation for Sovereign
Wealth Funds or Government Instrumentalities
High Net Worth Market Trends
· Tax-Inefficient Investment Strategies: Opportunistic credit, long-short equity, quantitative trading and direct lending
strategies
· Private bank and wire-house distribution platforms
Institutional Market
· Risk-Based Capital solutions
· Unrelated Business Taxable Income solutions
Next Steps
· Investors - Finding an Insurance Broker
· Investment Managers - Leveraging a Turnkey Platform
There will be no CE for this webinar
High Net Worth Market Trends
Institutional Market
Next Steps
There will be no CE for this webinar