Splitting the Dollar in Life, Death and Through the Generations
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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
