IRS taxes cash surrender value of split-dollar life policy placed in trust for benefit of executive.
The Tax Adviser › Vol. 28 Nbr. 2, February 1997
Linked as:
Summary
IRS Technical Advice Memorandum 9604001 extends its earlier analysis of the taxation of split-dollar life insurance arrangements by finding that cash surrender value increases in excess of amounts payable to the employer are currently taxable to the employee. In Revenue Ruling 64-328, the IRS identified that premium payments were taxable compensation to the extent they were made by the employer. In the 1996 ruling, the IRS found increases in cash surrender value to be property under IRC section 83.
See the full content of this document
Extract
IRS taxes cash surrender value of split-dollar life policy placed in trust for benefit of executive.
Until now, the IRS has not ruled on the more customary split-dollar plan in which an employer's interest is limited to its aggregate premium outlay and the remaining cash surrender value is payable to the employee. In Letter Ruling (TAM) 9604001, in which the life insurance policies were in trust, the Serv...
See the full content of this document
Sponsored links
