Ever since the Internal Revenue Service issued Notice 2001-101 in January of 2001, planners who advise clients on their split-dollar life insurance arrangements have had to deal with a Byzantine set of rules that yield different answers depending on the type of arrangement, when it was implemented, and if amended (also when). With the passage of Internal Revenue Code Section 409A and the issuance of Notice 2007-34,2 planners have to deal with a whole new set of
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