THE SPLIT DOLLARMINATOR! Using Commercial Lending to “Juice” the Funding of Loan Method Split Dollar Arrangements

Gerald Nowotny - Law Office of Gerald R. Nowotny
Contact

This article focuses on how a business can use a commercial loan to help finance a business’ obligation in a Loan Regime Split Dollar Arrangement and deduct the interest payments for its tax purposes, without running afoul of the limitations of IRC Sec. 264. The use of commercial lending provides an additional source of funding and leverage on an after-tax basis to provide funding for the purchase of life insurance policyholder using Loan Regime Split Dollar Arrangement.

Please see full publication below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Gerald Nowotny - Law Office of Gerald R. Nowotny | Attorney Advertising

Written by:

Gerald Nowotny - Law Office of Gerald R. Nowotny
Contact
more
less

Gerald Nowotny - Law Office of Gerald R. Nowotny on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide