Connelly denied relief for a life insurance-funded redemption agreement that flunked IRC § 2703, causing millions of dollars of estate tax to be paid. Given that the recent Huffman case injects significant uncertainty in any taxpayer being able to successfully navigate IRC § 2703, a life insurance redemption agreement is now riskier than it ever has been. Owners can reduce risk using a life insurance-funded cross-purchase agreement, but that raises other issues. This presentation covers practical issues raised by Connelly and Huffman, income tax and nontax issues raised by life insurance cross-purchase agreements, and how to use a life insurance LLC to better navigate a cross-purchase agreement.
Presentation Materials
Several thousand page PDF, which can be downloaded from the links below.
Newsletter ArticlesArticle on Connelly
