In PLR 200910002, the IRS ruled that the payment by both settlors of the premiums pursuant to a trust under a split-dollar life insurance arrangement will not result in a gift or a deemed gift to the trust by both settlors under section 2511. In addition, the IRS ruled that the proceeds of the policy payable to the trust under a split-dollar life insurance arrangement will not be included in the gross estate of either settlor under section 2042.
Posted by Min Young Choi, Associate Editor, Wealth Strategies Journal.
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This page contains a single entry by Associate Editor published on March 31, 2009 4:29 PM.
PLR 200910019: IRS Grants Extension to Make QDOT Election was the previous entry in this blog.
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PLR 200910002: IRS Rules on EGT Consequences of Split Dollar Arrangement
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