Podcast Center
Video Center
Webcasts
Resource Center
Events
April 02, 2008 at 12:08 AM
The Internal Revenue Service says taxpayers can make some changes to split-dollar life insurance arrangements without triggering “material change” rules.
If the parties to an arrangement change the arrangement without changing the underlying life insurance policy, the modification will not be treated as a material change for purposes of applying Section 101(j) and Section 264(f) of the Internal Revenue Code.
Section 101(j), added by the Pension Protection Act of 2006, limits the amount of tax-deductible life insurance benefits employers can get from corporate-owned life insurance, unless the insureds are directors, highly compensated employees, or current or recently departed employees. That rule grandfathers in life policies issued on or before Aug. 17, 2006.
