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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


- The one exception is non-equity donor/donee or employer/employee collateral
assignment arrangements



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Part 3 Split Dollar Webinar Series. ::Using Post-Final Regulation Loan Regime Arrangements




Recording and Slides are Available Here.



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Click here to see the Bundle of all 3 Split Dollar Webinars

Click here to see the Bundle of parts 2 and 3

• 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



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