Structuring Split-Dollar Life Insurance Arrangements after Estate of Levine v. Commissioner
Navigating Secs. 2036, 2038, and 2073 and Maximizing Tax Benefits of Split-Dollar Insurance Transactions
Recording of a 90-minute CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide estate planners and advisers with a thorough and practical guide to the use of split-dollar life insurance arrangements after the U.S. Tax Court holding in the Levine case. The panelist will offer specific guidance on drafting split-dollar agreements (SDAs) considering the court’s ruling and will give practitioners useful tools to structure the arrangements to conform with the favorable economic benefit doctrine.
- Benefits and complexities of the SDA
- Gift tax leverage
- Estate tax leverage
- Income tax impact of Levine
- Questions regarding the valuation of receivables under an SDA
- Key considerations and challenges
- Structuring the SDA
The panelist will discuss these and other important topics:
- What is the significance of the Tax Court's holding in Levine?
- How to structure an SDA so it avoids the more restrictive valuation rules
- What traps to avoid in the valuation of receivables arising from the purchase of the premiums in structuring an SDA?
- Under what client circumstances would the use of an SDA be most appropriate?
Gerald R. (Gerry) Nowotny, JD, LLM
Law Office of Gerald R. Nowotny
Mr. Nowotny has over 30 years in the insurance and financial planning industries. He has developed an expertise in tax... | Read More
Mr. Nowotny has over 30 years in the insurance and financial planning industries. He has developed an expertise in tax reduction and deferral strategies. Mr. Nowotny has developed a national reputation in private placement insurance products which are institutionally priced insurance products for ultra high net worth and institutional buyers. His expertise covers domestic and international applications with these products.Close
Chaim Borevitz, MBA, CBA
For over 20 years, Mr. Borevitz has valued all types of businesses, including manufacturing, wholesale, retail,... | Read More
For over 20 years, Mr. Borevitz has valued all types of businesses, including manufacturing, wholesale, retail, professional services, IT, bio-tech, entertainment/sports, and natural resources. His experience valuing intangibles goes beyond various types of equity, debt structures, and derivatives. Mr. Borevitz has valued artistic copyrights, licenses, and is a nationally recognized expert in the valuation of intangible assets related to split dollar life insurance. In addition to valuation services, he provides consulting and exit planning advisory services to business owners and PE firms.Close