Altair Advisers

Splitting the Dollar in Life, Death and Through the Generations

Date: Wednesday, September 21, 2022
Time: 12:00pm - 1:30pm
Location: University Club of Chicago, | 76 East Monroe Street | Cathedral Room - 9th Floor, Chicago, IL 60603
Speaker: Austin Fleming Award Recipient

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Buying a life insurance policy in the context of a split dollar arrangement has been available for many decades, although the current IRS rules were promulgated on September 18, 2003.  These rules apply to employer-employee relationships as well as to intra-family relationships, known as private split dollar.  The rules govern the two regimes under which a split dollar arrangement can be created: the loan regime and the economic benefit regime.  This presentation will examine and discuss split dollar in both employer-employee relationships as well as intra-family relationships and will explain the structure of the two split dollar regimes, as well as a less well-known, informal technique known as switch dollar, which can utilize the advantages of both, especially in the private split dollar arena.  The presentation will also detail a line of recent cases involving intergenerational split dollar, especially with regard to valuation issues at the death of the older generation.

Course Level:  Advanced

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