EXECUTIVE SUMMARY Many companies offer valued executives non-qualified benefits programs such as deferred compensation. While these programs are not eligible for funding through secured qualified plans, companies can…
Corporate Owned Life Insurance (COLI) – Overview
WHAT IS COLI? COLI is a funding strategy that has been broadly utilized by public and private companies, financial institutions, banks and insurance companies as a means of financing executive benefit obligations. COLI offers death benefit…
Implications of the Treasury Department’s Final Regulations on Reportable Policy Sales for 1035 Exchanges Made by Businesses
On October 31, the Treasury Department released its final regulations on Reportable Policy Sales (RPS). In addition to clarifying the tax implications for company-owned life insurance (“COLI”) and bank-owned life insurance (“BOLI”)…
Impact of Final Regulations on Reportable Policy Sales for COLI/BOLI Policies
Background The Tax Cuts and Jobs Act of 2017 (the “TCJA”) modified the prior-law exemptions of the Transfer for Value Rules (“TFV Rules”) to include new Reportable Policy Sale (“RPS”) requirements that apply to all transfers…
COLI Mechanics: Why Aggregate Funding?
Corporate-owned life insurance (“COLI”) is a financing alternative widely utilized by public and private companies, financial institutions, banks and insurance companies as a means of financing executive benefit obligations.