Rates for Imputed Income for Post 9-7-2003 Split Dollar Arrangements

Can an “insurer’s lower published premium rates” be used to determine the Cost of Insurance Protection under a split-dollar arrangement entered into after September 17, 2003?

This report investigates whether or not it is permissible to use an insurer’s lower published premium rates (instead of using IRS Table 2001) when computing imputed income under the economic benefit regime for a non-equity split-dollar life insurance arrangement entered into (or materially modified) after 9/17/2003.