Posts by Bill Hoisington

TAX DEVELOPMENTS IRS Releases 409A Corrections The Treasury and IRS published corrections to the final regulations that were published in April 2007 relating to IRC § 409A. The corrections were released and became effective July 31, 2007. The Treasury and IRS also published notice of proposed rulemaking regarding regulations under IRC § 402(a). The rules as…

TAX DEVELOPMENTS IRS Private Letter Ruling Regarding Exchange of Individual Certificates under a Master Group Contract In PLR 200715006, the IRS affirmed a corporate policy owner’s right to obtain IRC Section 1035 exchange tax treatment while exchanging individual certificates under a master group contract for individual policies. Although the IRS has not opined on this specific…

TAX DEVELOPMENTS IRS Releases Final Regulations under 409(A This month was somewhat quieter than recent months in terms of the number of noteworthy developments. The primary exception was publication by the IRS of the long anticipated final regulations under IRC Section 409A. The Groom Law Group prepared a number of publications which you may find helpful…

ACCOUNTING DEVELOPMENTS FASB EITF 06-10: Accounting for Collateral Assignment Split-Dollar Arrangements FASB reached a consensus on EITF 06-10 during its March 15 meeting. EITF 06-10 applies similar logic to accounting for collateral assignment split dollar plans as that espoused under EITF 06-4 with respect to endorsement split dollar. It was expected to be ratified by FASB…

ACCOUNTING DEVELOPMENTS FASB EITF 06-10: Accounting for Collateral Assignment Split-Dollar Arrangements On December 6, 2006, FASB released FASB EITF 06-10 (Draft Abstract). EITF 06-10 is very similar to EITF 06-04 (which dealt with endorsement split dollar) only it applies to collateral assignment split dollar plans. This summary authored by AALU provides additional information. The draft requested…