15 - 1 survivorship life characteristics also called second-to-die, last-to-die, joint life pays...
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15 - 1
Survivorship Life
Characteristics Also called second-to-die, last-to-die, joint life
Pays a death benefit upon the death of two or more insured’s dies
Basic policy is generally a traditional whole life, current assumption whole life or universal life When is the use of this tools indicated
To provide estate liquidity at the second death of a married couple
To protect two carrier families
To provide key person business insurance
In split dollar plans
To help fund charitable bequests
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Advantages Proceeds are payable when needed
If used in conjunction with the unlimited marital deduction
Premiums are lower than for equivalent coverage's in two separate policies
Number of alternative term/permanent life combinations Provide a wide latitude and flexibility in premium payment and death benefit
combinations
A lower “economic benefit” is reportable in split dollar plans
Medical underwriting standards are often eased
Disadvantages No benefits at the first death, if needed, without additional of a special rider In term/permanent plans, premiums could escalate if projected dividends are lower
than projected and/or term rates increase
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Disadvantages No benefits at the first death, if needed, without additional of a special rider
In term/permanent plans, premiums could escalate if projected dividends are lower than projected and/or term rates increase
Tax Implications General tax rules
Death benefits income tax free Death benefits subject to same income, estate, gift and generation skipping transfer
taxation rules as all other types of life insurance
Taxation of living proceeds Governed by IRC section 72 Payments separated into 3 categories
Annuity payments Payments of interest only Amounts not received as an annuity
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Tax Implications (cont'd) Annuity payments
Periodic payments received in a systematic liquidation of cash value
Each payment is treated partially as recovery of investment and partially as taxable interest
Once entire investment has been recovered, any further payments are treated entirely as taxable income
Payments of interest only Taxable income whether distributed or credited to account
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Tax Implications (cont'd) Amounts not received as an annuity
Taxed under the “cost recovery rule”
Included in gross income only to the extent they exceed the investment in the contract
Exceptions Modified Endowment Contracts
Cash distributions taxed under the interest first rule
Loan Proceeds If a loan is outstanding when a policy is surrendered, gains in the contract are
immediately recognized
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Tax Implications (cont'd) Split Dollar Plans
Economic benefit based on the joint and survivor rates based on U.S. Table 38
Significantly lower than for a single life
After the first death, the single life rates apply with respect to the survivor
Estate taxation Treated in the same manner as other types of life insurance
There may or may not be estate tax consequences at the first death, depending on who owns the policy
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Tax Implications (cont'd) Estate taxation (cont'd)
Policy may be owned in three ways By a third party
Exclusively by one or the other insured
Jointly by both insured
If neither insured has incidents of ownership and they have not transferred the policy within 3 years of death
Not included in the gross estate of either insured
Estate inclusion when policy owned by a corporation Policy included in estate of controlling shareholder if corporation has complete control
over policy or at least to borrow against policy
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Tax Implications (cont'd) Gift taxation
Parents may make tax-free joint gifts of up to $24,000 per beneficiary (2008) to help pay premium costs (if insured’s have no incidents of ownership in policy)
If annual gifts in excess of the annual gift tax exclusion amount are necessary, part of the unified gift and estate tax credit could be used so that gift taxes would not have to be paid
Making gifts to multiple beneficiaries can leverage amount qualifying for the annual gift tax exclusion
Alternatives Survivorship life is a unique life insurance policy
Only insurance alternative is to insure each life separately
Chapter 15Tools & Techniques of Life
Insurance Planning
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Survivorship Life
Alternatives Principal alternatives to pay estate taxes
Sell estate assets
Borrow money
Have cash readily available
Selecting the best policy Composition of the base policy
Traditional whole life
Current assumption whole life
Universal life
Chapter 15Tools & Techniques of Life
Insurance Planning