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Members of the American Bar Association, Section on Taxation
Jan. 7, 2003
30 pages; dated Dec. 31, 2002. Excerpt: On July 9, 2002, Treasury issued extensive proposed regulations concerning split-dollar life insurance arrangements and their treatment for income, payroll and transfer tax purposes. Consistent with Notice 2002-8, equity split-dollar life insurance arrangements would be subject to tax depending upon the ownership of the policy under one of two mutually exclusive regimes.
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