Designing a Generational Split-Dollar Plan

Much has been written about generational split-dollar (GSD).? Let’s take a fresh look at the 2016 Morrissette v. Commissioner, 2021 Morrisette v. Comm’r*, and Levine v. Comm’r cases in light of recent developments, including the Internal Revenue Service’s reported aggressive examination of GSD plans. I’ll review important aspects of these cases and offer a number of important GSD plan and policy design considerations.