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Side Fund Split Dollar Under The Loan Regime

A beneficial and flexible strategy.
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Split-dollar life insurance transactions can be an efficient technique1 to fund large life insurance death benefit amounts outside the insured’s estate even after the Treasury Regulations Sections 1.61-22 and 1.7872-15 were enacted in 2003. If the current higher exemption isn’t extended beyond its scheduled sunset at the end of 2025, or is reduced earlier, many more estates would benefit from the infusion of insurance liquidity that split dollar can efficiently facilitate.2<

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