In PLR 200947006, the IRS ruled that the proceeds of two whole life insurance policies received by a limited partnership on a taxpayer's death will not be included in the taxpayer's gross estate under sections 2042 and 2035(a) if the taxpayer relinquished powers over one of the policies during the 3-year period before their death.
See Tax Analysts: "IRS Addresses Treatment of Life Insurance Held by Partnerships and Trusts," 2009 TNT 223-50, November 23, 2009
Posted by Marc Patterson, Associate Editor, Wealth Strategies Journal.
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