Does anyone know if the IRS has prescribed (or hinted at) a definition of "nonrecourse" for purposes of the loan regime rules? (Or, for that matter, a definition of "recourse.") Example: collateral assignment split dollar, where the loan is always recourse, except it is nonrecourse if the executive is fired without cause. (Note: assume this is not a sham; executive has no effective control over his own firing.)

You might try searching the internet. I found several related responses, including Federal Estate & Gift Taxes, Michigan Bar handout and ALI-ABA. I also suggest Tax Facts, by National Underwriter.