COLI/BOLI

Tax Court Decides Purported Section 419(e) Plan is Both Deferred Compensation and Split-Dollar

Topics: COLI/BOLI, Estate planning, NQDC, Split-dollar

In this case, the Tax Court ruled that both the deferred compensation rules and the split-dollar life insurance regulations can apply to the same transaction in a manner that results in (1) disallowance of deductions for employer contributions and full income tax inclusion of the vested accrued benefits of highly compensated employees.

Tax Court Decides Purported Section 419(e) Plan is Both Deferred Compensation and Split-Dollar

Topics: COLI/BOLI, Estate planning, NQDC, Split-dollar

In this case, the Tax Court ruled that both the deferred compensation rules and the split-dollar life insurance regulations can apply to the same transaction in a manner that results in (1) disallowance of deductions for employer contributions and full income tax inclusion of the vested accrued benefits of highly compensated employees.

Key Employee Compensation 101- Favorable Economic Conditions Make Effective Key Employee Compensation Programs Critical.

Topics: COLI/BOLI, General life insurance, Policy loans

Effective key employee compensation programs serve a myriad of functions, such as recruitment, motivation, performance recognition, retention, alignment with shareholder interests, and succession planning. Program design options and benefits are voluminous and provide employers with extensive flexibility to meet the specific desires and needs of both the employer and the employees.

Employee Stock Ownership Plans – Tax Considerations & Planning for Repurchases.

Topics: COLI/BOLI, NQDC

Thursday, July 9, 2015WRM#15-25 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors.…

Better Consult the Oracle: 8 Key Questions for Code § 409A Compliance – The Gatekeeper to Structuring Effective Deferred Compensation Arrangements.

Topics: 409A, COLI/BOLI, NQDC

Thursday, June 11, 2015WRM#15-21 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors.…

Nonqualified Deferred Compensation Section 409A Compliance

Topics: 409A, COLI/BOLI, NQDC

A Chief Counsel Advice memorandum of the Internal Revenue Service advises that a pre-vesting plan correction will not “save” a nonqualified deferral plan’s failure to comply with Section 409A of the Internal Revenue Code (“Section 409A”) if benefits vest before the last day of the tax year in which the correction was made.

162 Bonus Plans – The Basics.

Topics: COLI/BOLI, NQDC

Thursday, May 28, 2015WRM#15-19 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors.…

The Transfer for Value Rule – A Primer.

Topics: COLI/BOLI, Transfer for value

Thursday, April 2, 2015WRM#15-12 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors.…

Death Benefit Only Plans – Not Dead Yet.

Topics: COLI/BOLI, General life insurance, NQDC

Thursday, March 5, 2015WRM#15-08 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors.…