Leveraging Life Insurance Premium Payments: Using Split-Dollar and Related Party Premium Financing Techniques

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.

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Split-dollar financing of life insurance premium payments is useful in any situation where one person or entity has the cash to pay the premiums and another person or entity has the need for life insurance coverage. In recent years, split-dollar arrangements have been used in a wealth transfer context, allowing the annual gift to the ILIT to be much less than the entire premium payment, because the employer, corporation or donor was entitled to recover its advances from the cash value or death benefit.

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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Table of Contents

TABLE OF CONTENTS

I. An Overview of Split-Dollar Premium Financing
II. Preliminary Matters
III. Uses of Leveraged Premium Financing Using Split-Dollar
IV. Premium Financing
V. Economic Benefit Split-Dollar
VI. "Grandfathered" Endorsement Split-Dollar Arrangements
VII. The Impact of Section 409A on Premium Financing and Economic Benefit Split-Dollar Arragnements
VIII. Conclusion
Appendix 1 - Table 2001
Appendix 2 - Comparison Table of Term Rates
Appendix 3 - Table 2001 Joint and Survivor Term Rates