TITLE

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

AUTHOR(S)
Brody, Lawrence
PUB. DATE
April 2000
SOURCE
Journal of Financial Planning;Apr2000, Vol. 13 Issue 4, p42
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
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.
ACCESSION #
3060562

 

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