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Important & Favorable Tax Court Split Dollar Ruling

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On April 13th, 2016, in Estate of Morrissette, the US Tax Court ruled in favor of the taxpayer in a generational split dollar situation. Following Mrs. Client’s death, the IRS assessed a gift tax deficiency of $13.8M and penalties of $2.7M. Ruling in favor of the taxpayer, the Court determined that a dynasty trust’s only economic benefit under the agreements was the current cost of life insurance protection. Note: This case did not address the valuation aspects of the estate’s interest in the generational split dollar plan.


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