Split dollar life insurance arrangements can take on a number of forms, and the exact structure of the arrangement determines the tax consequences, which can become complicated quickly. In a recent case out of the District Court of Ohio, the court held that an insurance arrangement between a single member C corporation, Peter E. McGowan…
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In a prior article, I wrote about the importance of properly prepared Form 706 Estate Tax Return, discussing a Private Letter Ruling (“PLR”) that highlighted some common mistakes made on the Form 706.[1] In that article, I discussed issues related to the marital deduction and the allocation of a decedent’s unused Generation Skipping Transfer Tax…
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In a recent Tax Court case[1], the Court held that the combined value of ten checks written prior to the decedent’s death, but cashed after his death, was included in the gross estate of the decedent. However, as discussed below, the IRS had conceded that three of the ten checks were not included in the…
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