WP90X – Intergenerational Split Dollar: Learning from Levine
May 14, 2024
Description:
Jason Prather, J.D., L.L.M, of Legacy Capital Group and Shane Swanson, J.D. of Stinson with Ryan Barradas of WealthPoint discuss Intergenerational Split-Dollar (IGSD) as an advanced estate planning strategy as well as the life insurance design utilized in their work on the Levine case. While IGSD is not a new concept, The Estate of Marion Levine vs. Commissioner of Internal Revenue Service decided in February 2022 has helped to define the proper way to use the strategy. When properly utilized, IGSD is very effective at both creating a reduction in the taxable estate of the wealthy senior generation, while also enhancing multi-generational tax planning.
This presentation highlights split-dollar regulations under which the plan in Levine was designed, as well as the restrictions that were used in the Split-Dollar Agreement in this case. The presenters discuss various challenges the IRS made as well as what differentiated this case from the Estates of Cahill and Morrissette involving a similar transaction.
Outline:
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