Split Dollar

News & Analysis as of

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Where Have You Gone Chico Escuela! Using Split Dollar Life Insurance for Major League Baseball Players

Overview - When I grew up in the Panama Canal Zone, the country of Panama still had winter league professional baseball up until 1970. They frequently played weekend games at the high school field down the street from my...more

Put Me in Coach! Using Split Dollar Life Insurance Plans to Compensate Division I Coaches

In August 2016, the national sports media provided details regarding the compensation package for Coach Jim Harbaugh at the University of Michigan. It comes as no surprise to anyone that Division I football and basketball...more

High Net Worth Family Tax Report, Vol. 11, No. 2

IRS Seeks to Limit Valuation Discounts for Family-Controlled Entities: Proposed Section 2704 Regulations - Proposed regulations issued on August 2, if finalized in their present form, will significantly limit the ability...more

Double Down! - Inter-Generational Split Dollar Throws Sand in the Face of the IRS Again

Recently I wrote an article on JD Supra called Split to Be Tied (May 4, 2016) regarding the Tax Court decision in Estate of Morrissette, (Estate of Clara M. Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016)). Once...more

Wealth Management Update - June 2016

June Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more

Split to Be Tied!

Looking Beyond the Morrissette Decision and Around the Corner for Inter-Generational Split Dollar - Overview - I have had the opportunity throughout my career to know top life insurance agents as well as several top...more

Tax Court Affirms Use of Intergenerational Split-Dollar Arrangements

The Tax Court, in its decision earlier this month in Estate of Morrissette, examined intergenerational split-dollar arrangements between a mother's revocable trust and three irrevocable dynasty trusts, one established for...more

Estate of Clara M. Morrissette Secures Victory in Groundbreaking Estate Tax Case

In a case of first impression, the United States Tax Court ruled in favor of a taxpayer whose estate planning focused on the preservation and succession of a 70-year-old family-owned business. In Estate of Clara M....more

Split-dollar Life Insurance – A Tax-Leveraged Derivative for Hedge Fund Managers

The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super...more

Can We Talk? Providing Hedge Fund Managers with the Deferral of Carried Interest until Eternity

Overview - The recent passing of Joan Rivers not only requires us to pay tribute to one of the great comedic minds of the last forty-fifty years, but serves as a testimony to professional passion, perseverance and hard...more

Tales from the Crypt -- Post-Mortem Planning Using Private Placement Insurance Products

Overview - This article discusses the use of private placement products - private placement deferred variable annuities (PPVA) and private placement life insurance (PPLI)- in post mortem income tax and transfer tax...more

Structured Settlement Planning for Trial Attorneys: The Benefits of Using Qualified Settlement Funds and Private Placement...

Overview - Trial attorneys are extremely vulnerable to a tax landscape that is becoming hostile territory. The result of the American Taxpayer Relief Act of 2013 (ATRA) is that earned income is taxed at substantially...more

Panning for Gold in the Ivory Tower – Using Split Dollar and Private Placement Life Insurance to Compensate Senior Executives of...

Overview - Charitable organizations from hospitals to universities have a difficult time attracting and retaining top executive talent from the world of public corporations. Public corporations provide competitive...more

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