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Split dollar life insurance guidance in IRS Notice 2001-10
Internal Revenue Service [IRS]
[Official Guidance] Jan. 11, 2001
The IRS has announced that it is reconsidering the treatment of split-dollar arrangements for the purchase of life insurance. Such arrangements are often used as a deferred compensation technique for executives, particularly among tax-exempt organizations. PS 58 costs may no longer be used to value the life insurance protection under the contract. The IRS is also focusing on (a) whether these arrangements give rise to loans under Code section 7872, and (b) how to treat equity-type life insurance contracts.
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