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If You Don’t Understand the New and Very Broad Life Insurance Transfer for Value Rules, You and Your Clients Could Be In Store for Some Serious Pain



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The Tax Cuts and Jobs Act amended Section 101 to deal with the transfer for value rule for reportable policy sales and added Section 6050Y to impose reporting requirements for reportable policy sales.  On October 25, the final treasury regulations were released, containing 120 pages of important content and rule changes.  The changes to the transfer for value rule are major and advisors need to understand these changes and how a simple change of ownership of a life insurance policy could fall under this new “reportable policy sale” definition and cause unneeded taxation of the death benefit.  These rules are not limited to the life settlement market, so all insurance producers, accountants, and attorneys need to understand the new rules because many transfers of policies that would not have previously been a transfer for value will now result in a transfer for value. 

This course will cover the following topics: 

·       Background on the transfer for value rule and what changes were made

·       What a reportable policy sale is and how it significantly changes the transfer for value rules going forward

·       What is a substantial family, business, or financial relationship, which is a key definition in determining if there has been a reportable policy sale

·       What are direct and indirect acquisitions of life insurance, such as acquiring an entity that owns life insurance policies

·       Application of the new rules to transfers of policies in estate planning cases

·       How the new rules impact transfers of policies in business planning cases

·       How the rules impact the life settlement market

·       Tax reporting requirements for reportable policy sales



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Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planners & Councils. He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. Mr. Keebler is the past Editor-in-Chief of CCH's magazine, Journal of Retirement Planning, and a member of CCH's Financial and Estate Planning Advisory Board. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration. Mr. Keebler frequently represents clients before the National Office of the Internal Revenue Service (IRS) in the private letter ruling process and in estate, gift and income tax examinations and appeals. In the past 20 years, he has received over 250 favorable private letter rulings including several key rulings of first impression. Mr. Keebler is nationally recognized as an expert in estate and retirement planning and works collaboratively with other experts on academic reviews and papers, and client matters. Mr. Keebler is the author of over 75 articles and columns and editor, author, or co-author of many books and treatises on wealth transfer and taxation, including the Warren, Gorham & Lamont of RIA treatise Esperti, Peterson and Keebler/Irrevocable Trusts: Analysis with Forms. Mr. Keebler is the Chair of the AICPA's Advanced Estate Planning Conference. He is a featured columnist for CCH's Taxes Magazine - Family Tax Planning Forum. Bob is also a contributing author to the American Bar Association's The ABA Practical Guide to Estate Planning. Robert.Keebler@KeeblerandAssociates.com


Michael Geeraerts, CPA, JD, CGMA, CLU is an advanced planning consultant at The Guardian Life Insurance Company of America. Prior to joining Guardian, Michael was a manager at PricewaterhouseCoopers LLP and a tax consultant at KPMG LLP. Michael’s experiences range from preparing tax returns for middle market companies, auditing mutual funds’ financial statements, to researching unique tax savings strategies for various companies. Michael has written articles for numerous national publications and has delivered continuing education courses to CPAs and attorneys on a variety of estate, business, and income tax planning strategies.


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