Client wants to transfer a whole life policy on his life to a profit sharing plan in which he is a participant. There is a PTE which allows the transfer subject to certain requirements dealing with value. Assume that is not at issue and that the ownership of the policy can be either personal or corporate.
Can he make it as an in kind contribution equal to the CSV? If the policy has no CSV, can it be transferred unilaterally? If it is transferred, do the transfer for value rules require that the portion of the Plan's death benefit attributable to the insurance policy be treated as income?