Planning with Intergenerational Split-Dollar After Cahill and Morrissette
The Tax Court’s recent opinion in Estate of Cahill v. Commissioner and an order in Estate of Morrissette v. Commissioner strongly suggest that the Court will reject a low estate tax value for a decedent's interest in a typical intergenerational split-dollar life insurance arrangement. In their exclusive LISI Webinar, Howard Zaritsky and Brent Berselli will review the Court's analysis and discuss how to modify the structure and operation of an intergenerational split-dollar arrangement to mitigate the problems raised in these cases. Here is just some of what Howard and Brent will cover:
- INTRODUCTION: Brief description of intergenerational split-dollar life insurance arrangements and what they are intended to achieve.
- INCOME AND GIFT TAX TREATMENT AND ESTATE OF MORRISSETTE: Discuss Morrissette and the income and gift tax advantages of the economic benefit regime.
- ESTATE TAX TREATMENT AND ESTATE OF CAHILL AND ESTATE OF MORRISSETTE II: Discuss Cahill and the application of Sections 2036, 2038, and 2703. Discuss order in Morrissette.
- AND NOW WHAT?
o Better Facts Would Help
o A Competent Donor
o A Business Purpose
o An Independent Trustee
o No Third-Party Loan
o What if the Agreement Does Not Permit Termination At All?
o Effect of Having the Agreement not Permit Termination or be silent as to termination?
o Effect of Using a Loan Repayable at the Insured’s Death and Bearing Long-Term AFR Interest
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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.