Table of Contents
Leveraging Life Insurance Premium Payments: Using Split-Dollar and Related Party Premium Financing Techniques examines and explains the peculiar rules for both of the premium financing regimes as well as the tax consequences and planning techniques of each. The tax and other issues affecting split-dollar arrangements grandfathered from the Final Split-Dollar Regulations are also analyzed.
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Predictions that 2003’s split-dollar regulations would destroy split-dollar financing have proved to be incorrect. In fact, split-dollar premium financing is more popular than ever. Leveraging Life Insurance Premium Payments: Using Split-Dollar and Related Party Premium Financing Techniques, Second Edition discusses the uses of premium loans (loan regime) and employer owned spilt-dollar (economic benefit regime) in such areas as deferred compensation, executive perks, business succession and wealth transfer. The book explores the differences between the regimes, their tax results and the reasons to use one over the other, as well as discussing their use with grantor trusts and intergenerational split-dollar arrangements.
This new edition contains a material discussion of the impact of the Levin, Cahill and Morrissette cases on intergenerational economic benefit regime split-dollar and the possible impact on the intergenerational loan regime split-dollar. It also includes analyses of the potential impact of IRC Section 409A and the status of grandfathered split-dollar arrangements. It is imperative that the advisor be familiar with the commonly used split-dollar techniques to properly advise a client on appropriate premium financing, and no other guide offers such a comprehensive explanation as Leveraging Life Insurance Premium Payments: Using Split-Dollar and Related Party Premium Financing Techniques, Second Edition.
ABA Book Publishing
9781639056163
194
5431141
7x10
5/29/2025 12:00:00 AM
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