Charitable Contributions Generally Must Be Reduced by Any Amount Received as Credit Against State or Local Taxes
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Copy of Form 8925 Employer Owned Life insurance Copy of Form 706 Estate Tax Return Copy of
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Private Placement Life Insurance & Annuities Private placement life insurance and annuities can provide income tax efficiency,as well as investment
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Private placement life insurance and annuities can provide income tax efficiency,as well as investment flexibility, asset protection and financial privacy.Chiefly, they allow the insured to have for more influence over the investment portfolio held within the contract. They are often used in conjunction with tax inefficient investments, like hedge funds, to curtail the tax liability.
What is Split-Dollar? A split-dollar arrangement is an agreement between two parties (such as a business and employee) to split
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A split-dollar arrangement is an agreement between two parties (such as a business and employee) to split the costs and benefits of a life insurance policy insuring the life of one of the parties (e.g.,the employee).
One party funds all or most of the policy premiums, retaining a right to repayment upon termination of the arrangement, which is generally paid from or secured by the proceeds of the policy.
At the death of the insured or the prior termination of the arrangement (sometimes referred to as split-dollar “exit” or “roll-out”), the premium advancer is reimbursed for the premiums it paid (plus any additional amounts required by the agreement), while the other party retains the remaining death benefit, or, in the case of a lifetime termination, the policy (and depending on the arrangement, any remaining policy cash value).
146 T.C. No. 11 UNITED STATES TAX COURT ESTATE OF CLARA M. MORRISSETTE, DECEASED, KENNETH MORRISSETTE, DONALD J. MORRISSETTE, AND
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ESTATE OF CLARA M. MORRISSETTE, DECEASED, KENNETH
MORRISSETTE, DONALD J. MORRISSETTE, AND ARTHUR E.
MORRISSETTE, PERSONAL REPRESENTATIVES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4415-14.
Filed April 13, 2016.
In 2006 D’s revocable trust, T, entered into two split-dollar life insurance arrangements with three distinct trusts. T then contributed a total of $29.9 million to the trusts in order to fund the purchase of life insurance policies on each of D’s three sons. The split-dollar life insurance arrangements provided that T would receive the greater of the cash surrender value of the respective policy or the aggregate premium payments on that policy upon termination of the split-dollar life insurance arrangement or the death of the insured.
R determined that the $29.9 million contribution was a gift for tax year 2006. R determined a gift tax deficiency against E, the estate of D, of $13,800,179 and an I.R.C. sec. 6662 penalty of $2,760,036. E moved for partial summary judgment under Rule 121 on the narrow issue of whether the split-dollar life insurance arrangements are governed by the economic benefit regime under sec. 1.61-22, Income Tax Regs.
