THE INTERNAL Revenue Service recently issued Notice 2002-8,[1]� which revokes previously issued Notice 2001-10,[2]� its controversial split-dollar life insurance guidance from last year. The notice announces the intent to publish proposed regulations providing comprehensive guidance on the tax treatment of split-dollar life insurance arrangements, outlines rules that are expected to be included in the forthcoming proposed regulations, and offers interim guidance regarding the valuation of current life insurance protection in such arrangements. This article provides a primer on the taxation of split-dollar arrangements, summarizes Notice 2002-8 and describes the treatment of both new and pre-existing split-dollar arrangements in light of the Notice.
IRS Rulings
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