Embed construction in the Split Dollar Agreement

Aug 6th, 2022
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How to embed construction in the Split Dollar Agreement

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This month at Life Insurance Strategies Group, were seeing an increase in the use of intergenerational split dollar, which is a strategy for estate and wealth transfer. Over the last few years, the tax court has made a number of decisions which have reinforced the security of intergenerational split dollar. So what is intergenerational split dollar? Well, its a version of private split dollar and it works like other split dollar plans do, in that there is a sharing of how premiums and and insurance policys proceeds are split. There is a state and gift tax exemption amount of just over $12 million per person right now. This will sunset at the end of 2025 to $5 million indexed for inflation over a few years. This means that it makes it very difficult to get a large amount of money out of ones estate. So one way to do it is to freeze the amount of funds by making a personal loan to a trust to use for estate planning. When those funds move into the trust, theyre frozen in value. They

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ENDORSEMENT SPLIT DOLLAR: The employer owns the policy and endorses a portion of the death proceeds to the employees beneficiary. The employer is treated as giving economic benefits to the employee.
Some potential disadvantages of split dollar life insurance include complex tax implications, potential disputes over policy ownership, limitations on the employees ability to access cash value, and the need for careful planning to ensure compliance with applicable regulations.
In a split dollar arrangement the employer is offering a loan to the employee which is utilized to pay the premium of a life insurance policy. The employee owns the life insurance contract, names a personal beneficiary and assigns the policy as collateral to the employer, in return for the employers premium payments.
Reverse split-dollar policies require the employer contributes to the term life portion of the policy, while the employee is responsible for the cash value part of the premium.
Its an agreement to share a life insurance policy between two (or more) parties. Usually, one pays the premium and both sides get some of the benefits paid upon the insureds death.
Final regulations provide two types of split-dollar life insurance arrangements: economic benefit regimes and loan regimes.
The two types of split-dollar plans are economic benefit arrangements (economic benefit regimes) and loan arrangements (loan regimes).
Employers are responsible for making split-dollar life insurance premiums, regardless of the plans type. However, it is important to note that under loan arrangements, employees must repay the premiums via collateral assignments made to their employer.

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