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split-dollar life insurance arrangement

Tax Court – donee received only life insurance protection, so split dollar economic benefit regime applied

Tax Court – donee received only life insurance protection, so split dollar economic benefit regime applied

Estate of Morrissette, (2016) 146 TC No. 11 The Tax Court has examined the terms of a split dollar life insurance arrangement, determined that the party that received the funds to pay the premiums from the other party received no economic benefit other than current life insurance protection, and therefore ruled that the “economic benefit […]

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Tax Court -purported welfare benefit plans were nonqualified deferred compensation arrangements

Tax Court -purported welfare benefit plans were nonqualified deferred compensation arrangements

Machacek, Jr., TC Memo 2016-55 In consolidated cases, the Tax Court has concluded that purported welfare benefit plans in which the taxpayers’ companies participated were nonqualified deferred compensation arrangements, and the taxpayers had to include in their gross income any vested accrued benefits in the plan under Code Sec. 402(b)(4), because the plan failed to […]

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Tax Court – Purported welfare benefit plan was split-dollar life insurance arrangement

Tax Court – Purported welfare benefit plan was split-dollar life insurance arrangement

Our Country Home Enterprises, Inc., et al., 145 TC No. 1 In consolidated cases, the Tax Court has concluded that the life insurance policies issued on the lives of shareholder/employees incident to their participation in a purported welfare benefit plan were part of a split-dollar life insurance arrangement. Further, the Court determined that the corporate […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney