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Split-Dollar Life Insurance Planning After the Levine Case
April 5, 2022 @ 4:00 pm – 5:30 pm EDT
A recent Tax Court case gave a resounding victory to the taxpayer who had pursued what some might view as an aggressive split-dollar life insurance plan to minimize estate taxes. Estate of Marion Levine v. Commr. 158 T.C. No. 2, February 28, 2022. This webinar will set the stage with a review of split-dollar planning then analyze the case. This follows prior cases that held against other taxpayers using similar techniques. Understanding what the taxpayer did right in the Levine case, and how that contrasts to what taxpayers did wrong in a prior case, Estate of Cahill, can be used to guide taxpayers contemplating such planning. But even better guidance is possible. A careful reading of the Levine case to identify steps the Levine Court found favorable, might be used to craft a roadmap of how to implement a similar plan. Importantly, the lessons in the roadmap that will be discussed should be considered by taxpayers undertaking almost any type of estate planning. While aspects of the Levine opinion are pretty narrowly limited to the split-dollar insurance technique used in the case, many have broad applicability. The IRS arguments and Tax Court’s response regarding code sections 2036, 2038 and 2703 will be reviewed.
Continuing Education Credits
InterActive Legal is not an approved Continuing Education (CE) Sponsor. However, several states and regulatory agencies for a variety of professionals that participate on our teleconferences may still receive continuing education credit for their participation. If a participant wishes to receive CE credit for their participation in these teleconferences, they must apply to receive credit on their own and through their individual states and regulatory authorities. It is the responsibility of the participant to file for CE credit and is not guaranteed by the webinar sponsors.
Mr. Blattmachr is a Principal in ILS Management, LLC and a retired member of Milbank Tweed Hadley & McCloy LLP in New York, NY and of the Alaska, California and New York Bars. He is recognized as one of the most creative trusts and estates lawyers in the country and is listed in The Best Lawyers in America. He has written and lectured extensively on estate and trust taxation and charitable giving.
Martin M. Shenkman is an attorney in private practice in Fort Lee, NJ, and New York City. His practice concentrates on estate and tax planning, planning for closely held business, and estate administration. Mr. Shenkman is an author of over 42 books and more than 1,000 articles. He is an editorial board member of Trusts & Estates Magazine and the Matrimonial Strategist, and an advisor for InterActive Legal. He is the recipient of many awards including being a 2013 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planning Counsels. Mr. Shenkman was named Financial Planning Magazine 2012 Pro-Bono Financial Planner of the Year for his efforts on behalf of those living with chronic illness and disability. Investment Adviser Magazine featured him on the cover of its April 2013 issue naming as the lead of their “all-star lineup of tax experts.”
Lawrence M. Lipoff, CPA, TEP, CEBS, is a Director in CohnReznick’s Trusts and Estates Practice, based in the firm’s New York office. With more than 30 years of experience, Larry specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. Larry provides strategic advice to his clients and their closely-held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value.