Special Bundle of 3 Webinars:
Split Dollar Series Parts 1, 2 and 3
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
After you pay you will be sent a link with the registration information. If you have any questions, please contact webinaradmin@leimbergservices.com
NOTE: To pay using a credit card, use the botton labeled
"Pay with Debit or Credit Card"
after clicking the Buy Now button below.
If you are a LISI member, please login below to receive the member price of $295.00 $245.00 for this bundle of 3 webinars.
Part 2 Split Dollar Webinar Series. : Using Post-Final Regulation Economic Benefit Regime Split-Dollar 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
Click here to see the Bundle of parts 2 and 3
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
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
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