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Designing a Generational Split-Dollar Plan

Careful planning, implementation and administration are needed.

Much has been written1 about generational split-dollar (GSD).2 Let’s take a fresh look at the 2016 Morrissette v. Commissioner,3 2021 Morrisette v. Comm’r4 and  Levine v. Comm’r cases5 in light of recent developments, including the Internal Revenue Service’s reported aggressive examination of GSD plans. I’ll review important aspects of these cases and offer a number of important GSD plan and policy design

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