Leveraging Life Insurance Premium Payments: Using Split-Dollar and Related Party Premium Financing Techniques

Split-dollar financing of life insurance premium payments is useful in any situation where one person or entity has the cash to pay the premiums and another person or entity has the need for life insurance coverage. In recent years, split-dollar arrangements have been used in a wealth transfer context, allowing the annual gift to the ILIT to be much less than the entire premium payment, because the employer, corporation or donor was entitled to recover its advances from the cash value or death benefit. Leveraging Life Insurance Premium Payments: Using Split-Dollar and Related Party Premium Financing Techniques clearly examines and explains the peculiar rules for each of the two premium financing regimes that came into effect with the Final Split-Dollar Regulations in 2003 -- the loan regime, the most prevalent form of split-dollar financing, and the economic benefit regime. The book's authors, both acknowledged authorities on the use of life insurance in estate and employee benefit financing, also consider for each of these regimes the appropriate situations, the tax consequences, and optimum planning techniques. In addition, the tax and other issues affecting split-dollar arrangements grandfathered from the Final Split-Dollar Regulations are also analyzed.