Split-dollar life insurance.

AuthorLaffie, Lesli S.
PositionFrom The IRS

Notice 2002-59 explains the standards for valuing current life insurance protection under a split-dollar life insurance arrangement. The guidance intends to stop the spread of an abusive tax avoidance transaction using split-dollar life insurance, in which the parties attempt to avoid taxes by using inappropriately high current term insurance rates, premium prepayments or other techniques to understate the value of taxable policy benefits.

A party participating in a split-dollar life insurance arrangement may use the premium rates in Notice 2002-8's Table 2001 or the insurer's lower published premium rates only to value current life insurance protection for Federal tax purposes when (and to...

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