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There are 2 types of split dollar plans. Collateral assignment / loan regime. Endorsement split dollar / economic benefit regime.
The endorsement split dollar plan is one that is owned by the employer. The premiums are paid by the employer and the beneficiary is listed as the employee.
Disadvantages of split dollar life insurance plans Your business will generally receive no tax deduction for its share of premium payments under the split dollar plan. Depending on how the agreement is structured, employees may have to pay income taxes each year on the value of the economic benefits provided to them.
Disadvantages of split dollar life insurance plans Your business will generally receive no tax deduction for its share of premium payments under the split dollar plan. Depending on how the agreement is structured, employees may have to pay income taxes each year on the value of the economic benefits provided to them.
If the employer is the owner of the split-dollar policy, the employers premium payments are treated as providing taxable economic benefits to the executive.

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Split-dollar agreements look a lot like interest-free loans. The IRS, however, took the position in the 1964 Revenue Ruling that split-dollar arrangements would be considered by the IRS to be a taxable fringe benefit to the employee rather than an interest-free loan.
A split-dollar policy is not an insurance policy but refers to a contract between the parties that sets out their duties to split the costs and their rights to share in the proceeds of an insurance policy.
An insured person may enter into an arrangement with family members or a trust for the familys benefit, but most split-dollar plans involve a fringe benefit program in which an employer assists an employee in purchasing an insurance policy on the life of the employee for the benefit of the employees family.
Disadvantages of split dollar life insurance plans Your business will generally receive no tax deduction for its share of premium payments under the split dollar plan. Depending on how the agreement is structured, employees may have to pay income taxes each year on the value of the economic benefits provided to them.
If the employer is the owner of the split-dollar policy, the employers premium payments are treated as providing taxable economic benefits to the executive. The economic benefits include the executives interest in the policys accessible cash value and current life insurance protection.

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