Relief for Failure to File Written Representations with the IRS for Split-Dollar Loans

more+
less-

In several recent private letter rulings, the Internal Revenue Service has granted extensions to taxpayers to file written representations for split-dollar loans. By being covered under a private letter ruling, affected employees were able to avoid significant tax increases of taxable compensation for all prior periods.

Parties to a split-dollar life insurance arrangement (SDA) who fail to timely file written representations with the Internal Revenue Service (IRS) for split-dollar loans may not be out of luck. Filing written representations with the IRS for split-dollar loans is not always applicable, but it can be very beneficial to an employee to do so. In several recent private letter rulings, the IRS granted extensions to taxpayers to file these representations. By being covered under a private letter ruling, affected employees were able to avoid significant increases of taxable compensation for all prior periods. We suggest reviewing whether written representations have been timely filed for split-dollar loans that are repayable solely from a life insurance policy, because administrative relief may be available to avoid adverse tax and reporting consequences for the parties. The remainder of this On the Subject describes the following:...

Please see full article 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.

© McDermott Will & Emery | Attorney Advertising

Written by:

more+
less-

McDermott Will & Emery on:

JD Supra Readers' Choice 2016 Awards
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:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×