Combining the benefits of a QPRT with a life insurance trust

Article Abstract:

The author discusses a method of combining a qualified personal residence trust with a life insurance trust in order to transfer property to an irrevocable trust instead of the grantor's children. Topics include how the combination strategy work, likely candidates for combination, and qualifying as a grantor trust.

Laws, regulations and rules, Real estate, Real property, Trusts and trustees, Trustees, Trusts (Law)

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IRS ruling taxes plan as both split-dollar and interest-free loan

Article Abstract:

The author discusses a 2000 IRS ruling that funds paid to a split-dollar insurance arrangement, created in conjunction with the sale of a medical practice, were taxable as an interest-free loan.

Tax planning

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Family split-dollar produces gift, estate, and GST tax advantages

Article Abstract:

Split-dollar life insurance policies can effectively be used for general estate planning benefits and specifically to avoid estate taxes on proceeds of life insurance. IRS letter rulings 9636033 and 9745019 provide favorable guidance regarding Family Split-Dollar policies and trust transactions which open up many planning avenues. Qualified terminable interest property (QTIP) and generation-skipping tax are issues which are involved in such planning.

Estate Planning, Planning, Estate tax, Estate taxes

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