Part 1 of 3 Part SPLIT-DOLLAR WEBINAR SERIES:
THE SPLIT-DOLLAR ďFIX ITĒ SHOP Ė WHAT TO DO WITH PRE-FINAL
REGULATION SPLIT-DOLLAR ARRANGEMENTS
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
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