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This is a bit like the comment Fermat made in the margin of a book concerning an easy to understand numerical theorem (there is no combination of a, b and c (all positive integers) for which an = bn + cn, where n is a positive integer greater than 2) that became known as "Fermat's Last Theorem" and which took 350 years to prove. After stating the theorem, he wrote "I have discovered a truly marvelous proof of this, which this margin is too narrow to contain." In this instance, my mind is too narrow to be concerned with the proper taxation of life insurance policies that had been held in a 401(k) plan, or I would be clamoring for your answer.

Yes - Endorsement Method Split Dollar. Employer owned policy. Employer is endorsing a percent of the death benefit, in this case 100%, to the employee to designate the beneficiary. Employee is receiving an Economic Benefit and should be charged an imputed income accordingly.

QDRO, you've been blowing that horn beautifully for years, and I agree with you, but while you may save a few souls here and there the reality is that the PS will be the PA 99.9% of the time.