- 8 - extent that the policy’s cash surrender value5 exceeded the termination account value. The policy’s cash surrender value did not exceed its termination account value during the years in issue. Under the DBOA, as long as the annual premium of $40,000 was paid, the Addis family trust was entitled to receive a death benefit of $434,509 plus any increase in the death benefit from the initial death benefit of $991,789. Under the DBOA, the Addis family trust was required to pay the premiums on the policy if the cumulative premiums were inadequate to fund NHF’s cost of insurance. 8. Enactment of Section 170(f)(10) in 1999 Petitioners stopped making payments to NHF after 1998. NHF no longer participates in charitable split-dollar life insurance arrangements because of the enactment in 1999 of section 170(f)(10),6 which requires charities to pay a 100-percent excise tax on certain life insurance premium payments. 5 A policy’s cash surrender value is its total gross cash value less any surrender charges imposed by the insurer on the surrender of the policy. 6 Sec. 170(f)(10) was added to the Code by sec. 537(a) of the Ticket to Work and Work Incentives Improvement Act of 1999, Pub. L. 106-170, 113 Stat. 1860, 1936, generally effective for transfers after Feb. 8, 1999.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011