Endorsement Split-Dollar Life insurance

[Steelerfan]

Does anyone have familiarity with the exemption from FICA tax under 3121(a)(2)© for employer paid life insurance (other than group term life insurance over 50,000) where the benefit is available to employees in general or to a class of employees.

For example where a split dollar life insurance program is implemented for employees who are senior vice presidents and above with x years of service, this would seem to be a class of employees. Does anyone see why the exemption from FICA tax would not apply to the amount imputed into income as the economic benefit to employees or retirees who hold policies?