IRS Position on Group-Term Carve-Out Split-Dollar Plans

Brody, Lawrence
April 2000
Journal of Financial Planning;Apr2000, Vol. 13 Issue 4, p42
Academic Journal
This article discusses the implication of the issuance of the U.S. Internal Revenue Service's Technical Advice Memorandum (TAM) 200002047 on split-dollar arrangement for senior executives. The specific issue raised in the memorandum is whether the amount includible in the participating employees' income as a result of the plan should be the rules of Section 79 which relates to group term insurance. The conclusion provided was that the split-dollar arrangement provided to the officers was in fact a group term. The implications of this TAM for both group term carve-out arrangements and for other group split-dollar arrangements are potentially' serious.


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