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IRS Releases Proposed Regs on Split-Dollar Insurance Arrangements
Internal Revenue Service [IRS] 
[Official Guidance] July 5, 2002
Excerpt: As indicated in Notice 2002-8, the proposed regulations provide two mutually exclusive regimes for taxing split-dollar life insurance arrangements. A split-dollar life insurance arrangement (as defined in the proposed regulations) is taxed under either the economic benefit regime or the loan regime.... Thus ... the proposed regulations generally provide substantially different tax consequences to the parties depending on which party owns the life insurance contract.
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