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Parts of this article are from book published by BISK Education CPEasy: CPAs Guide To Life Insurance authored by Lance Wallach IRC Sections 419(e) and 419A(f)(6) Plans For years life insurance agents and others have been selling ways to deduct life insurance in welfare benefit plans. For years the IRS has been disallowing most of these plans on audit.In Notice 2007-83, the IRS identified certain trust arrangements involving cash value life insurance policies, and substantially similar arrangements, as listed transactions. The IRS also issued related Revenue Ruling 2007-65 to address situations where an arrangement is considered a welfare benefit fund but the employer's deduction for its contributions to the fund is denied in whole or in part for premiums paid by the trust on cash value life insurance policies.The IRS ruled in Revenue Ruling 2007-65 that a welfare benefit fund's qualified direct cost under IRC §419 does not include premium amounts paid by the fund for cash value life insurance policies if the fund is directly or indirectly a beneficiary under the policy as determined under IRC §264(a).If a transaction is designated as a listed...more
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