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ABA
Joint Committee on Employee Benefits
The Sections of Business Law, Health Law, Labor and Employment
Law,
Real Property, Probate and Trust Law, Taxation and Tort Trial
and Insurance Practice
and The American College of Employee Benefits Counsel Present
Split Dollar Arrangements: What Now?
A 90-minute Teleconference / Audio
Webcast
Tuesday, October
28, 2003
1:00-2:30 pm ET / 12:00-1:30 pm
CT / 11:00 am-12:30 pm MT / 10:00 am-11:30 am PT
This program has
already taken place.
Audiotapes are available for $150.
For ordering information, contact Nancy Matthews at matthewsn@staff.abanet.org
or (202) 662-8640.
Ref. #JCEBT031028SDSA
The IRS has issued its final regulations
addressing the federal tax treatment of split-dollar life
insurance arrangements. The final regulations will apply to
split-dollar arrangements entered into after September 17,
2003, as well as existing arrangements that are "materially
modified" after that date. Certain transition safe harbors
will continue to govern existing arrangements, but the availability
of the transition rules will, for the most part, expire on
December 31, 2003.
The SEC has not been forthcoming on the treatment of split-dollar
arrangements under Section 402 of the Sarbanes-Oxley Act of
2002, which prohibits publicly-traded companies from providing
personal loans to directors and executive officers. Although
violations of these new prohibitions are treated as criminal
acts, private practitioners responsible for advising clients
must interpret ambiguous statutory provisions without the
benefit of legislative history or regulatory guidance. Now
that the end of the year is approaching, what should companies
do about their existing split-dollar arrangements? How should
practitioners advise their clients on the thorny issues presented
under Section 402? Is there any future for split-dollar arrangements?
Topics Include:
- The "Loan Regime" and the "Economic
Benefit Regime"
- Practical Consequences of Final Regulations
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- Interpretive Issues Under Sarbanes-Oxley Act
- Structure and Use of "Safe Harbors"
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Moderator
Linda Shore, Buchanan Ingersoll, Washington, DC
Speakers
Michael Doran, Attorney-Advisor, U.S. Department of
Treasury, Washington, DC
Doreen Devine, AON Consulting, Washington, DC
Stuart Lewis, Buchanan Ingersoll, Washington, DC
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