Like many non-qualified plans,
split dollar arrangements can be a very useful tool for employers looking to provide additional benefits to key employees (See also: How Non Qualified Deferred Compensation Plans Work.)
Things get a bit more uncertain for
split dollar arrangements involving partnerships and LLCs because the IRS rules are very unclear about how to classify the life insurance benefits.
This regime generally governs the taxation of compensatory arrangements in which the employee is not the owner of the contract (e.g., endorsement
split dollar arrangements).
In a typical
split dollar arrangement, the employer funds all or part of the cost of providing an employee with life insurance protection and then recoups the cost by sharing in the insurance proceeds at the employee's death.
A closely held business (hereafter «employer»), can pay the entire premium pursuant to
a split dollar arrangement.
Usually, parties to
a split dollar arrangement are a closely held or family business and a key employee.
Usually, parties to
a split dollar arrangement are a closely held or family business and a key employee.
With
the split dollar arrangement, the premium payer, generally the insured's company, is entitled to the cash value or an amount equal to the cash value from the death proceeds.
Not exact matches
especially valuable in a
split -
dollar business
arrangement, equals the policy's face amount plus the adjusted total premium (total premiums paid, less any partial surrenders).
To be clear,
split -
dollar life insurance is not an insurance product but rather an
arrangement to purchase and fund life insurance between two parties, generally an employee and an employer.
Split -
Dollar Plan Generally used in business situations, a life insurance
arrangement whereby the ownership and benefits of a policy as well as the obligation to pay premiums are divided or
split between an employer and employee.
The IRS recently has announced changes in the taxation of
split -
dollar plans, and these changes cast doubt on the future utility of some of these
arrangements and create a risk of potentially disastrous tax consequences for participants in certain existing
split -
dollar arrangements.
An insured person may enter into an
arrangement with family members or a trust for the family's 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 employee's family.
These employment - related
split -
dollar arrangements were sometimes used as a method of deferred compensation and sometimes as an estate - planning technique for the insured employee.
Under this
split dollar life insurance
arrangement, the employer retains a security interest in order to be repaid.
Survivorship
split dollar life insurance is an
arrangement in which two parties
split the costs and benefits of a survivorship life insurance policy.
(See Chapter 41 for a further discussion of
split dollar life insurance
arrangements.)