De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021): Split-dollar Insurance Benefits Were Compensation, Not a Distribution

The U.S. Tax Court in De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021), issued a “reviewed opinion” holding that economic benefits received by the taxpayer-husband under a split-dollar arrangement were not “distributions” under Code Sec. 301, but were benefits received under a compensatory arrangement and as such were taxable as “compensation for services” under section 61(a)(1) as ordinary income.

See full opinion by clicking De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021): Split-dollar Insurance Benefits Were Compensation, Not a Distribution.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.

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