The final regulations provide guidance for loans made pursuant to a split-dollar life insurance arrangement. To obtain a particular treatment under the regulations for certain split- dollar loans, the parties to the loan must make a written representation, which must be kept as part of their books and records and a copy filed with their federal income tax returns. In addition, if a split-dollar loan provides for contingent payments, the lender must produce a projected payment schedule for the loan and give the borrower a copy of the schedule. This schedule is used by parties to compute their interest accruals and any imputed transfers for tax purposes.
US Code:
26 USC 61
Name of Law: Gross income defined
US Code:
26 USC 83
Name of Law: Property transferred in connection with performance of services
US Code:
26 USC 301
Name of Law: Distributions of property
US Code:
26 USC 7872
Name of Law: Treatment of loans with below-market interest rates
US Code:
26 USC 6103
Name of Law: Confidentiality and disclosure of returns and return information
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
1545-1792_supporting_statement_20141230.doc
Final_Reg-164754-01.pdf
REG-164754-01 (FINAL) Split-Dollar Life Insurance Arrangements