IRS Proposes Big Split-Dollar Changes
National Underwriter (Life and Health Financial Services Edition) (07/08/02) p.D2; Brostoff, Steven

The Internal Revenue Service's proposed rule changes for split-dollar life insurance arrangements could place the policies in two tax regimes: an economic benefit regime or a loan regime. Under the economic benefit regime, the owner of the life insurance contract would be treated as providing economic benefits to the non-owner, versus the loan regime, under which the non-owner would be treated as lending premium payments to the owner. If passed, the rule would impact employers and employees that divide the expense and benefits of owning life insurance policies that insure workers.

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