Using Life Settlement Transactions to Value Split-Dollar Loan Receivables Large Estates For large estates which often plan on using life insurance with large premiums to reduce the value of the estate, split-dollar life insurance offers an attractive method for funding the premiums with favorable gifting consequences.  However, the IRS has begun cracking down on the…

IRS Valuation Discounts At the American Bar Association meeting in May 2015, Cathy Hughes, Estate and Gift Tax Attorney of the US Department of Treasury’s Office of Tax Policy, commented that proposed amendments to Section 2704 (the IRS code that deals with valuation discounts) could be out by mid-September 2015.  While the IRS has yet…

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