Split dollar life insurance taxation

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Split dollar life insurance is a popular strategy used by individuals and businesses to fund life insurance policies. It involves an agreement between two parties, typically an employer and an employee, where the costs and benefits of a life insurance policy are split between them. However, the taxation of split dollar life insurance can be complex and requires careful consideration. In this article, we will explore the various aspects of split dollar life insurance taxation and provide a comprehensive understanding of the topic.

Understanding Split Dollar Life Insurance

Before delving into the taxation aspects, it is essential to have a clear understanding of split dollar life insurance. Split dollar life insurance is a financial arrangement where two parties collaborate to fund a life insurance policy. The two common types of split dollar arrangements are the economic benefit regime and the loan regime.

Under the economic benefit regime, one party pays the premiums for the life insurance policy, while the other party is entitled to the death benefit. The party paying the premiums is considered the policy’s owner and may have certain rights and access to the policy’s cash value. The party entitled to the death benefit is typically the insured individual or their designated beneficiary.

In the loan regime, one party provides a loan to the other party to pay the premiums. The loan is secured by the cash value of the life insurance policy and is typically repaid upon the insured’s death. The party providing the loan may charge interest on the loan amount.

Taxation of Split Dollar Life Insurance

The taxation of split dollar life insurance depends on several factors, including the type of split dollar arrangement, the ownership of the policy, and the premium payments. Here are some key considerations:

Imputed Income: Under the economic benefit regime, the party entitled to the death benefit may be subject to imputed income. The imputed income is calculated based on the value of the death benefit and the cost of the life insurance protection. This imputed income is generally taxable to the recipient.

Policy Loans: In the loan regime, if the party providing the loan charges interest, the interest income may be taxable to the borrower. However, if the loan is structured as a below-market loan, the borrower may be subject to imputed interest income.

Transfer for Value Rule: The transfer for value rule is an important consideration in split dollar arrangements. It states that if a life insurance policy is transferred for valuable consideration, such as a sale or exchange, the death benefit proceeds may be subject to income tax. However, certain exceptions apply, such as transfers to the insured, a partner of the insured, or a corporation in which the insured is a shareholder.


In conclusion, split dollar life insurance can be an effective strategy for funding life insurance policies. However, the taxation of split dollar arrangements requires careful attention. The imputed income, policy loans, and transfer for value rule are important considerations that can impact the tax implications of split dollar life insurance. It is crucial to consult with a qualified tax professional or financial advisor to ensure compliance with tax laws and to optimize the tax benefits of split dollar arrangements.


– IRS: Split Dollar Life Insurance – https://www.irs.gov/businesses/small-businesses-self-employed/split-dollar-life-insurance
– Investopedia: Split Dollar Life Insurance – https://www.investopedia.com/terms/s/split-dollar-life-insurance.asp
– The National Law Review: Split Dollar Life Insurance Arrangements – Tax and Other Considerations – https://www.natlawreview.com/article/split-dollar-life-insurance-arrangements-tax-and-other-considerations