Executive Trifecta® for Key Executives Executive Trifecta is a vital new concept in executive benefit planning.
Download ReportTranscript Executive Trifecta® for Key Executives Executive Trifecta is a vital new concept in executive benefit planning.
Slide 1
Executive Trifecta®
for
Key Executives
Slide 2
Executive Trifecta is a vital new concept in executive
benefit planning. It can be used selectively for owner or
non-owner executives of C Corporations, S Corporations,
Limited Liability Companies, and Partnerships.
Slide 3
Background
Most firms would not consider operating without
insuring against the loss of its property.
The same logic should apply to its human capital -a far more vital asset to the successful continuation
of any business.
Slide 4
Background
If an executive is valuable enough to have life insurance
coverage to indemnify the business, that individual should
also be provided with unique executive fringe benefits.
The reverse is also true -If an executive is valuable enough to be provided with
unique executive fringe benefits, that individual should also
have life insurance coverage to indemnify the business.
Too often, one is provided without regard for the other –
and the fusion of both concepts can be dynamic.
Slide 5
“Trifecta” refers to a winning sequence of three -and Executive Trifecta delivers three, very powerful,
sequential benefits:
Selected key executives are insured in favor of the employer;
In pre-retirement years, a portion of each policy’s death
benefit is allocated to provide survivor income benefits to
the insured executive’s family;
At each key executive’s retirement, disability, or involuntary
severance without cause, the life insurance policy is
contractually transferred to the executive (as a deferred
bonus) thereby creating a supplemental retirement asset.
Slide 6
The reasons to allocate a portion of the policy’s preretirement death proceeds for the benefit of the employer
are as follows:
Recover the costs of locating a replacement;
Recover the costs of a signing bonus;
Recover the costs of a relocation package;
Recover the loss of profits while a replacement gets “up to speed”;
Recover the permanent loss of profits if the executive is "irreplaceable";
Assure creditors and suppliers that loans and receivables are safe;
Assure customers that the business will continue its operations;
Fund a buyout if the executive is a shareholder.
Slide 7
The reasons to allocate a portion of the policy’s preretirement death proceeds for the benefit of the executive’s
family are as follows:
Provide an inexpensive source of continuing family income;
Provide the executive with relief from purchasing expensive personal
life insurance coverage.
Slide 8
The reasons to transfer ownership of the policy to the
executive at retirement are as follows:
Provide the executive with after tax retirement cash flow by way of
policy withdrawals and/or loans;
Provide income tax free death benefits for the executive’s family.
Slide 9
Basic Variation
Key Executive Coverage
With the Basic Variation, the user inputs the amount of life
insurance coverage to indemnify the employer against the loss
of the key executive under the module’s Key Executive
Coverage tab.
This provides much simpler data entry when that amount is
known in advance (e.g., stock redemption coverage or a clientdesignated number).
Slide 10
Advanced Variation
Key Executive Coverage
With the Advanced Variation, the System calculates the amount
of life insurance coverage used to indemnify the employer against
the loss of the key executive.
This is done via user-entered estimates as to how long it will take
a replacement executive to match the performance of the
deceased executive.
The System also calculates differences in expected compensation
between the two executives.
Slide 11
Basic and Advanced Variations
Survivor Income Benefit and Policy Transfer
With either Variation, the System calculates the amount of
coverage to fund the survivor income benefit as well as the
tax details of the transfer of the policy to the participant at
retirement (or at an earlier date such as achieving specific
sales, revenue, or profit goals).
Slide 12
Main Menu
(Illustration Data)
Click on the Blue buttons for direct access or continue
through the participant examples one screen at a time.
Shareholder -- C Corporation
Shareholder -- S Corporation
Member -- Limited Liability Company
Partner -- Partnership
Non-Shareholder Executive -- C Corporation
Non-Shareholder Executive -- S Corporation
Non-Member Executive -- Limited Liability Company
Non-Partner Executive -- Partnership
Tax Notes
Balance of the Presentation
Slide 13
Executive Trifecta
Shareholder Executive of C Corporation
At retirement, the Corporation distributes the policy as
compensation. The executive has taxable income to the
extent of the policy’s fair market value -- which is its cash
value without reduction for surrender charges (IRS Rev.
Proc. 2005-25).
Note: The personal taxation is the same for a non-shareholder executive.
The Corporation must recognize any gain to the extent that
the cash value of the policy exceeds the Corporation’s
premium payments; however, the Corporation is entitled to
a deduction under IRC Section 162 equal to the amount the
executive includes in income.
Slide 14
Results for Tom Cabot, Age 45, a Key Shareholder
Executive of Ferris Metallurgical, Inc.
(C Corporation)
Ferris Metallurgical’s pre-retirement annual premium: $25,000
Ferris Metallurgical’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Tom’s services: $1,000,000
Portion allocated for survivor benefit for Tom’s family: $529,322
Tom’s pre-retirement survivor benefit: $100,000 a year for 10 years
Tom’s income tax when policy is transferred: $382,785
Tom’s policy withdrawal to pay the tax: $382,785
Tom’s post-retirement annual premium: $0
Tom’s personal death benefit starting at age 65: $1,000,000+
Tom’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
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to review the illustration.
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Slide 15
Executive Trifecta
Shareholder Executive of S Corporation
At retirement, the S Corporation distributes the policy to the
Shareholder as a K-1 distribution, and any gain is recognized by
the Corporation as if the property were sold at fair market value - which is its cash value without reduction for surrender charges
(IRS Rev. Proc. 2005-25).
The gain passes through to the Shareholder as ordinary income
under the built-in gains rules (IRC Secs. 311(b), 1366(a)(1) and
1374). In other words, a Shareholder of an S Corporation pays
income tax only on the gain in the policy -- not on the entire
cash value as is the case with a C Corporation.
The Shareholder’s basis in the policy is its cash value on the
date of transfer without reduction for surrender charges.
Slide 16
Results for Joe Mason, Age 45, a Key Shareholder
Executive of Advantis Software, Inc.
(S Corporation)
Advantis Software’s pre-retirement annual premium: $25,000
Advantis Software’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Joe’s services: $1,000,000
Portion allocated for survivor benefit for Joe’s family: $529,322
Joe’s pre-retirement survivor benefit: $100,000 a year for 10 years
Joe’s income tax when policy is transferred: $201,848
Joe’s policy withdrawal to pay the tax: $201,848
Joe’s post-retirement annual premium: $0
Joe’s personal death benefit starting at age 65: $1,200,000+
Joe’s tax free retirement cash flow at age 65: $80,000 for 20 yrs.
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to review the illustration.
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Slide 17
Executive Trifecta
Member of Limited Liability Company
When the LLC distributes the policy to the Member as a
K-1 distribution at retirement, no gain or loss need be
recognized by the LLC on a distribution of property or
money to a Member (IRC Sec. 731(b)).
Likewise, no gain or loss need be recognized by the
Member receiving the policy, regardless of whether the
value of the policy is higher or lower than the Member’s
adjusted basis in the Member’s interest in the Company
(IRC Sec. 731(a)).
Slide 18
Results for Harvey Scott, Age 45, a Key
Member of Scott Engineering, LLC
(Limited Liability Company)
Scott Engineering’s pre-retirement annual premium: $25,000
Scott Engineering’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Harvey’s services: $1,000,000
Portion allocated for survivor benefit for Harvey’s family: $529,322
Harvey’s pre-retirement survivor benefit: $100,000 a year for 10 years
Harvey’s income tax when policy is transferred: $0
Harvey’s policy withdrawal to pay the tax: N/A
Harvey’s post-retirement annual premium: $0
Harvey’s personal death benefit starting at age 65: $1,400,000+
Harvey’s tax free retirement cash flow at age 65: $100,000 for 20 yrs.
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Slide 19
Executive Trifecta
Partner of Partnership
When the Partnership distributes the policy to the Partner
as a K-1 distribution at retirement, no gain or loss need
be recognized by the Partnership on a distribution of
property or money to a Partner (IRC Sec. 731(b)).
Likewise, no gain or loss need be recognized by the
Partner receiving the policy, regardless of whether the
value of the policy is higher or lower than the Partner’s
adjusted basis in the Partner’s interest in the Partnership
(IRC Sec. 731(a)).
Slide 20
Results for Jeremy Baker, Age 45, a Key Partner
of Baker, Simms, and Caldwell (“BS&C”)
(Partnership)
BS&C’s pre-retirement annual premium: $25,000
BS&C’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Jeremy’s services: $1,000,000
Portion allocated for survivor benefit for Jeremy’s family: $529,322
Jeremy’s pre-retirement survivor benefit: $100,000 yr. for 10 yrs.
Jeremy’s income tax when policy is transferred: $0
Jeremy’s policy withdrawal to pay the tax: N/A
Jeremy’s post-retirement annual premium: $0
Jeremy’s personal death benefit starting at age 65: $1,400,000+
Jeremy’s tax free retirement cash flow at age 65: $100,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 21
Executive Trifecta Illustrations
Taxation: Non-Shareholder Executive
C Corporation: At retirement, the policy is distributed to the
participating non-shareholder executive as compensation. The
executive has taxable income to the extent of the policy’s fair market
value -- which is generally approximated by the policy’s cash value
without reduction for surrender charges (IRS Rev. Proc. 2005-25).
Note: A non-shareholder executive of a C Corporation has identical
personal taxation as a non-owner executive of any other type of business.
In the year of policy distribution, the Corporation must recognize any
gain to the extent that the cash value of the policy exceeds the
Corporation’s premium payments; however, the Corporation is
entitled to a deduction under IRC Section 162 equal to the amount
the executive includes in income.
Slide 22
Results for Mark Fox, Age 45, a Key NonShareholder Executive of Ferris Metallurgical, Inc.
(C Corporation)
Ferris Metallurgical’s pre-retirement annual premium: $25,000
Ferris Metallurgical’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Mark’s services: $1,000,000
Portion allocated for survivor benefit for Mark’s family: $529,322
Mark’s pre-retirement survivor benefit: $100,000 a year for 10 years
Mark’s income tax when policy is transferred: $382,785
Mark’s policy withdrawal to pay the tax: $382,785
Mark’s post-retirement annual premium: $0
Mark’s personal death benefit starting at age 65: $1,000,000+
Mark’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
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Slide 23
Executive Trifecta Illustrations
Taxation: Non-Shareholder Executive
S Corporation: At retirement, the policy is distributed to a
participating non-shareholder executive as compensation. The
executive has taxable income to the extent of the policy’s fair
market value -- which is generally approximated by the policy’s
cash value without reduction for surrender charges (IRS Rev.
Proc. 2005-25).
Note: A non-shareholder executive of an S Corporation has identical
personal taxation as a non-owner executive of any other type of business.
In the year of policy distribution, all shareholders are entitled to a
deduction equal to their proportionate share of the distributed
policy’s fair market value, and any gain will pass through to the
shareholders pro rata as ordinary income under the built-in gains
rules (IRC Secs. 311(b), 1366(a)(1) and 1374).
Slide 24
Results for Bruce Michaels, Age 45, a Key NonShareholder Executive of Advantis Software, Inc.
(S Corporation)
Advantis Software’s pre-retirement annual premium: $25,000
Advantis Software’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Bruce’s services: $1,000,000
Portion allocated for survivor benefit for Bruce’s family: $529,322
Bruce’s pre-retirement survivor benefit: $100,000 a year for 10 years
Bruce’s income tax when policy is transferred: $382,785
Bruce’s policy withdrawal to pay the tax: $382,785
Bruce’s post-retirement annual premium: $0
Bruce’s personal death benefit starting at age 65: $1,000,000+
Bruce’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 25
Executive Trifecta Illustrations
Taxation: Non-Member Executive
Limited Liability Company: At retirement, the policy is distributed
to the participating non-member executive as compensation. The
executive has taxable income to the extent of the policy’s fair market
value -- which is generally approximated by the policy’s cash value
without reduction for surrender charges (IRS Rev. Proc.2005-25).
Note: A non-member executive of a Limited Liability Company has identical
personal taxation as a non-owner executive of any other type of business.
In the year of policy distribution, all members are entitled to their
proportionate share of a deduction equal to the distributed policy’s
fair market value.
Slide 26
Results for Alan Johnson, Age 45, a Key NonMember of Scott Engineering, LLC
(Limited Liability Company)
Scott Engineering’s pre-retirement annual premium: $25,000
Scott Engineering’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Alan’s services: $1,000,000
Portion allocated for survivor benefit for Alan’s family: $529,322
Alan’s pre-retirement survivor benefit: $100,000 a year for 10 years
Alan’s income tax when policy is transferred: $382,785
Alan’s policy withdrawal to pay the tax: $382,785
Alan’s post-retirement annual premium: $0
Alan’s personal death benefit starting at age 65: $1,000,000+
Alan’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 27
Executive Trifecta Illustrations
Taxation: Non-Partner Executive
Partnership: At retirement, the he policy is distributed to a
participating non-partner executive as compensation. The
executive has taxable income to the extent of the policy’s fair
market value -- which is generally approximated by the policy’s
cash value without reduction for surrender charges (IRS Rev.
Proc.2005-25).
Note: A non-partner executive of a Partnership has identical personal
taxation as a non-owner executive of any other type of business.
In the year of policy distribution, all partners are entitled to their
proportionate share of a deduction equal to the distributed
policy’s fair market value.
Slide 28
Results for Ted Coombs, Age 45, a Key NonPartner of Baker, Simms, and Caldwell (“BS&C”)
(Partnership)
BS&C’s pre-retirement annual premium: $25,000
BS&C’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Ted’s services: $1,000,000
Portion allocated for survivor benefit for Ted’s family: $529,322
Ted’s pre-retirement survivor benefit: $100,000 a year for 10 years
Ted’s income tax when policy is transferred: $382,785
Ted’s policy withdrawal to pay the tax: $382,785
Ted’s post-retirement annual premium: $0
Ted’s personal death benefit starting at age 65: $1,000,000+
Ted’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
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Slide 29
Tax Notes
Click here
to review Tax Notes regarding:
Tax details of the plan for various business entities (C Corp,
S Corp., LLC, Partnership) based on a participant’s relationship
to those entities;
Suitability of the plan based on the type and size of a business.
Note: Transfer taxation for shareholders of an S Corporation is
different based on the number of shareholders participating in the
plan. Be sure to review Sections 2a, 2b, and 2c of the Tax Notes
file for details (including the Notes that follow Section 2c).
Main Menu ->
Slide 30
Excess Compensation
Shareholder Executive of a C Corporation: Executive Trifecta can
produce substantial cash values for this participant at the point the
policy is transferred to the executive. Such sums should not
necessarily trigger excess compensation because the agreement to
transfer would likely have been in effect for many years and
therefore covers many years of service. A client’s legal and tax
counsel should be specifically consulted on this issue.
Excess compensation should not an issue for pass-through entities
such as S Corporations, Limited Liability Companies, and
Partnerships.
Slide 31
Policy Death Benefit
Prior to the distribution of the policy to the insured participant, the
entire death benefit of the policy funding an Executive Trifecta
arrangement is payable to the business entity in order to provide it
with funds to 1) indemnify the business against the loss of services
of the insured participant and 2) informally fund the payment of a
Survivor Income Benefit to the insured participant’s family.
The policy death benefit received should be income tax free to the
business entity under IRC Section 101(a) provided that the
appropriate notice and consent documents have been executed as
required by IRC Section 101(j)(4) as well as the reporting
requirements required by IRC Section 6039I.
Slide 32
Policy Death Benefit
(continued)
The notice and consent requirements of IRC Sec. 101(j)(4) are
met if, before the life insurance policy is issued, the employee:
is notified in writing that the employer intends to insure the
employee’s life and the maximum face amount of the coverage
at the time the coverage is issued;
gives written consent to being insured under the contract and
continuation of such coverage after the insured employee
terminates employment; and
is informed in writing that the employer will be a beneficiary of
death proceeds from the policy.
Slide 33
Policy Death Benefit
(continued)
With respect to IRC Section 6039I, an employer that, after August
17, 2006, has one or more employer-owned life insurance contracts
must file a return that shows for each year the policy is owned:
the number of employees employed at the end of the year;
the number of employees insured under employer-owned life
insurance contracts at the end of the year;
the total amount of insurance in force under such contracts at the
end of the year;
the name, address, and taxpayer identification number of the
employer and the type of business in which the employer is
engaged; and
that the employer has a valid consent for each insured employee.
Slide 34
Policy Death Benefit
(continued)
Record Keeping Requirement – Any employer (or other applicable
policyholder) that owns one or more employer-owned life insurance
contracts during the year must keep whatever records are
necessary to determine whether the requirements of the IRC
Sections 6039I and 101(j) are met.:
A specimen “Company-Owned Life Insurance - Notice and Consent
Form” (as required by IRC Section 101(j)) and a specimen
“Company-Owned Life Insurance - Annual Reporting Form” (as
required by IRC Section 6039I) are in the Executive Trifecta
document set and in the Special Files section of InsMark’s
Documents On A Disk and Documents On The Net Systems
(Versions 17.0 and higher).
Slide 35
Policy Death Benefit
(continued)
Regardless of the business entity, the Survivor Income Benefit paid
to an insured participant’s family when the insured dies prior to
distribution of the policy should be deductible by the business when
paid (IRC Sec. 404(a)(5)) and taxable as ordinary income to the
recipient(s). The survivor benefits are subject to tests of reasonable
compensation (IRC Sec. 162).
Note re Shareholders of S Corporations, Members of Limited
Liability Companies, and Partners of Partnerships: Legal and tax
advisers may find it advantageous to treat the death benefit
proceeds allocated for the survivor income benefit as a lump sum
K-1 distribution.
Slide 36
Policy Death Benefit
(continued)
After the policy is transferred to the insured (typically at retirement),
any subsequent death benefit payable to that participant’s
beneficiaries should be income tax free under IRC Section 101(a).
Slide 37
Retirement Cash Flow
After policy ownership is transferred to the insured (typically at
retirement), any withdrawals of cash values or dividends from the
policy by the participant should be income tax free to the extent
they do not exceed the insured’s basis. Any policy loans should
also be income tax free (provided the policy stays in force).
Slide 38
Illustration Resources
Licensees for Version 15.0 (and higher) of the InsMark
Illustration System can review all the menu input for the
Executive Trifecta illustrations in this presentation by double
clicking on the file named Executive Trifecta (PPT).!II located
in the following directory of your computer:
C:/insmark/workbook
Close this presentation before launching that file.
If you are not licensed for the InsMark Illustration System, call
InsMark at 1-888-InsMark (467-6275) for licensing information.
Slide 39
Specimen Documentation
Specimen documentation for Executive Trifecta can be found in Version
17.0 of InsMark’s Documents On A Disk® (“DOD”) System and Documents
On The Net® System (“DON”).
The InsMark Illustration System has a link to these documents on the lower
right side of the Workbook window (when in Edit mode in the Executive
Trifecta module).
Version 18.0 of DOD and DON (due for release in the 2nd Quarter of 2008)
has more comprehensive documentation for S Corporations, Limited
Liability Companies, and Partnerships. If you are a user authorized to
receive Version 18.0 and would like copies of such documentation prior to
the release, contact InsMark at 1-888-InsMark (467-6275).
If you are not licensed for either DOD or DON, call InsMark at 1-888InsMark (467-6275) for licensing information.
Slide 40
IRC Section 409A
Executive Trifecta falls under the purview of IRC Section 409A;
however, provided the plan is properly designed, documented,
and administered, there should be no adverse affects relative
to Sec. 409A that should apply.
Executive Trifecta works because, even though it may fail the
substantial risk of forfeiture test and be characterized as
deferred compensation under IRC Section 409A, it meets the
election and distribution requirements of Section 409A, thus
allowing for deferral of income.
Slide 41
IRC Section 409A
(continued)
Under the regulations, it appears that a plan may fail to have a
substantial risk of forfeiture under Section 409A but have a
substantial risk of forfeiture under IRC Section 83, thus being
deferred compensation for income tax purposes but a welfare
plan for ERISA purposes.
Unless the IRS provides future guidance to the contrary,
Executive Trifecta would be deemed to have a substantial risk
of forfeiture for Section 83 and ERISA purposes, and the plan
would meet the deferred compensation requirements of
Section 409A.
Slide 42
Sarbanes-Oxley Act
Since Executive Trifecta does not involve loan funding of premiums,
it is unaffected by the provisions of Sarbanes-Oxley that prohibit
loan-based split dollar. Consequently, it is available for executives of
publicly-owned companies as well as private ones.
Split Dollar
Executive Trifecta has no split dollar features and should be
unaffected by the U. S. Treasury Department’s Final Split Dollar
Regulations issued in September 2003.
Slide 43
Suitability - Type of Business
C Corporation: A C Corporation can retain its net profits as
operating capital or merely to strengthen the balance sheet;
however, a C Corporation is taxed at the corporate level on net
profits. If net profits are then distributed as dividends, the
shareholder(s) are again taxed. If all net after tax profits are
distributed, there are no funds left to provide the Executive
Trifecta for anyone, and it is unlikely that such a C Corporation
can utilize Executive Trifecta.
The ideal C Corporation candidate for Executive Trifecta is one
that requires a strong balance sheet and therefore retains a
portion of net profits.
Slide 44
Suitability - Type of Business
(continued)
S Corporation, Limited Liability Company, Partnership:
These pass-through entities, like C Corporations, can decide to
retain net profits as operating capital or merely to strengthen
the balance sheet. However, all profits are considered as if
they were distributed to shareholders, members, or partners,
as the case may be, and are income taxable to those
individuals. As a result, most pass-through entities distribute at
least an amount of net profits to cover the income tax. If the
remaining net profits are also distributed, there are no funds
left to provide the Executive Trifecta benefit for anyone.
The ideal pass-through entity candidate for Executive Trifecta
is one that retains a portion of net profits.
Slide 45
Suitability - Size of Business
With standard deferred compensation arrangements, there
may be a concern that a business may not survive the death of
its owner(s) resulting in an absence of the continuity of
management needed to fulfill retirement income commitments.
With Executive Trifecta, the policy values that fund the insured
participant’s retirement cash flow are generated from a life
insurance policy that has been contractually transferred to that
participant, and the continuation of the business thereafter is
irrelevant to that cash flow.
Slide 46
Suitability - Size of Business
(continued)
Continuity of management concerns can be avoided with the
survivor income benefit associated with Executive Trifecta by
scheduling the payment to the insured’s family in a lump sum.
Note: Legal and tax advisers may find it advantageous to treat
the death benefit proceeds allocated for the survivor income
benefit as a lump sum K-1 distribution for principals of S
Corporations, Limited Liability Companies, and Partnerships.)
Slide 47
Important Notice
Examples and case studies are for illustration purposes.
Actual results may vary. Legal and tax information is for
general use only and may not be applicable to specific
circumstances. Clients should consult their own legal, tax
and accounting advisors to assist in the evaluation of any
potential transaction or strategy.
Policy loans reduce policy cash values and death benefits,
and the lapse of a loaned policy could result in severe tax
ramifications to the policy owner. Be sure to consult a
professional tax adviser if you have questions about this.
Slide 48
Circular 230 Disclosure
In order to ensure compliance with requirements imposed by
the IRS under Circular 230, any U.S. Federal tax advice or
information contained in this communication is not intended or
written to be used, and cannot be used, for the purpose of
(1) avoiding penalties under the Internal Revenue Code or
(2) promoting, marketing or recommending to another party
any matters addressed herein.
Slide 49
Circular 230 Disclosure
(continued)
In the event that this document (including any attachments,
enclosures, or referred material) is also considered to be a
“marketed opinion” within the meaning of the IRS guidance,
then, as required by the IRS, please be further advised that
the material contained herein is written to support the
promotions or marketing of the transactions or matters
addressed by the material contained herein, and, based on
the particular circumstances, you should seek advice from an
independent tax adviser.
Slide 50
“InsMark”, “Executive Trifecta”, and “Documents On A Disk”
are registered trademarks of InsMark, Inc.
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Clip art may not be reused without written authorization from its owner.
Copyright 2006-2008, InsMark, Inc.
All Rights Reserved
Executive Trifecta®
for
Key Executives
Slide 2
Executive Trifecta is a vital new concept in executive
benefit planning. It can be used selectively for owner or
non-owner executives of C Corporations, S Corporations,
Limited Liability Companies, and Partnerships.
Slide 3
Background
Most firms would not consider operating without
insuring against the loss of its property.
The same logic should apply to its human capital -a far more vital asset to the successful continuation
of any business.
Slide 4
Background
If an executive is valuable enough to have life insurance
coverage to indemnify the business, that individual should
also be provided with unique executive fringe benefits.
The reverse is also true -If an executive is valuable enough to be provided with
unique executive fringe benefits, that individual should also
have life insurance coverage to indemnify the business.
Too often, one is provided without regard for the other –
and the fusion of both concepts can be dynamic.
Slide 5
“Trifecta” refers to a winning sequence of three -and Executive Trifecta delivers three, very powerful,
sequential benefits:
Selected key executives are insured in favor of the employer;
In pre-retirement years, a portion of each policy’s death
benefit is allocated to provide survivor income benefits to
the insured executive’s family;
At each key executive’s retirement, disability, or involuntary
severance without cause, the life insurance policy is
contractually transferred to the executive (as a deferred
bonus) thereby creating a supplemental retirement asset.
Slide 6
The reasons to allocate a portion of the policy’s preretirement death proceeds for the benefit of the employer
are as follows:
Recover the costs of locating a replacement;
Recover the costs of a signing bonus;
Recover the costs of a relocation package;
Recover the loss of profits while a replacement gets “up to speed”;
Recover the permanent loss of profits if the executive is "irreplaceable";
Assure creditors and suppliers that loans and receivables are safe;
Assure customers that the business will continue its operations;
Fund a buyout if the executive is a shareholder.
Slide 7
The reasons to allocate a portion of the policy’s preretirement death proceeds for the benefit of the executive’s
family are as follows:
Provide an inexpensive source of continuing family income;
Provide the executive with relief from purchasing expensive personal
life insurance coverage.
Slide 8
The reasons to transfer ownership of the policy to the
executive at retirement are as follows:
Provide the executive with after tax retirement cash flow by way of
policy withdrawals and/or loans;
Provide income tax free death benefits for the executive’s family.
Slide 9
Basic Variation
Key Executive Coverage
With the Basic Variation, the user inputs the amount of life
insurance coverage to indemnify the employer against the loss
of the key executive under the module’s Key Executive
Coverage tab.
This provides much simpler data entry when that amount is
known in advance (e.g., stock redemption coverage or a clientdesignated number).
Slide 10
Advanced Variation
Key Executive Coverage
With the Advanced Variation, the System calculates the amount
of life insurance coverage used to indemnify the employer against
the loss of the key executive.
This is done via user-entered estimates as to how long it will take
a replacement executive to match the performance of the
deceased executive.
The System also calculates differences in expected compensation
between the two executives.
Slide 11
Basic and Advanced Variations
Survivor Income Benefit and Policy Transfer
With either Variation, the System calculates the amount of
coverage to fund the survivor income benefit as well as the
tax details of the transfer of the policy to the participant at
retirement (or at an earlier date such as achieving specific
sales, revenue, or profit goals).
Slide 12
Main Menu
(Illustration Data)
Click on the Blue buttons for direct access or continue
through the participant examples one screen at a time.
Shareholder -- C Corporation
Shareholder -- S Corporation
Member -- Limited Liability Company
Partner -- Partnership
Non-Shareholder Executive -- C Corporation
Non-Shareholder Executive -- S Corporation
Non-Member Executive -- Limited Liability Company
Non-Partner Executive -- Partnership
Tax Notes
Balance of the Presentation
Slide 13
Executive Trifecta
Shareholder Executive of C Corporation
At retirement, the Corporation distributes the policy as
compensation. The executive has taxable income to the
extent of the policy’s fair market value -- which is its cash
value without reduction for surrender charges (IRS Rev.
Proc. 2005-25).
Note: The personal taxation is the same for a non-shareholder executive.
The Corporation must recognize any gain to the extent that
the cash value of the policy exceeds the Corporation’s
premium payments; however, the Corporation is entitled to
a deduction under IRC Section 162 equal to the amount the
executive includes in income.
Slide 14
Results for Tom Cabot, Age 45, a Key Shareholder
Executive of Ferris Metallurgical, Inc.
(C Corporation)
Ferris Metallurgical’s pre-retirement annual premium: $25,000
Ferris Metallurgical’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Tom’s services: $1,000,000
Portion allocated for survivor benefit for Tom’s family: $529,322
Tom’s pre-retirement survivor benefit: $100,000 a year for 10 years
Tom’s income tax when policy is transferred: $382,785
Tom’s policy withdrawal to pay the tax: $382,785
Tom’s post-retirement annual premium: $0
Tom’s personal death benefit starting at age 65: $1,000,000+
Tom’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 15
Executive Trifecta
Shareholder Executive of S Corporation
At retirement, the S Corporation distributes the policy to the
Shareholder as a K-1 distribution, and any gain is recognized by
the Corporation as if the property were sold at fair market value - which is its cash value without reduction for surrender charges
(IRS Rev. Proc. 2005-25).
The gain passes through to the Shareholder as ordinary income
under the built-in gains rules (IRC Secs. 311(b), 1366(a)(1) and
1374). In other words, a Shareholder of an S Corporation pays
income tax only on the gain in the policy -- not on the entire
cash value as is the case with a C Corporation.
The Shareholder’s basis in the policy is its cash value on the
date of transfer without reduction for surrender charges.
Slide 16
Results for Joe Mason, Age 45, a Key Shareholder
Executive of Advantis Software, Inc.
(S Corporation)
Advantis Software’s pre-retirement annual premium: $25,000
Advantis Software’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Joe’s services: $1,000,000
Portion allocated for survivor benefit for Joe’s family: $529,322
Joe’s pre-retirement survivor benefit: $100,000 a year for 10 years
Joe’s income tax when policy is transferred: $201,848
Joe’s policy withdrawal to pay the tax: $201,848
Joe’s post-retirement annual premium: $0
Joe’s personal death benefit starting at age 65: $1,200,000+
Joe’s tax free retirement cash flow at age 65: $80,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 17
Executive Trifecta
Member of Limited Liability Company
When the LLC distributes the policy to the Member as a
K-1 distribution at retirement, no gain or loss need be
recognized by the LLC on a distribution of property or
money to a Member (IRC Sec. 731(b)).
Likewise, no gain or loss need be recognized by the
Member receiving the policy, regardless of whether the
value of the policy is higher or lower than the Member’s
adjusted basis in the Member’s interest in the Company
(IRC Sec. 731(a)).
Slide 18
Results for Harvey Scott, Age 45, a Key
Member of Scott Engineering, LLC
(Limited Liability Company)
Scott Engineering’s pre-retirement annual premium: $25,000
Scott Engineering’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Harvey’s services: $1,000,000
Portion allocated for survivor benefit for Harvey’s family: $529,322
Harvey’s pre-retirement survivor benefit: $100,000 a year for 10 years
Harvey’s income tax when policy is transferred: $0
Harvey’s policy withdrawal to pay the tax: N/A
Harvey’s post-retirement annual premium: $0
Harvey’s personal death benefit starting at age 65: $1,400,000+
Harvey’s tax free retirement cash flow at age 65: $100,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 19
Executive Trifecta
Partner of Partnership
When the Partnership distributes the policy to the Partner
as a K-1 distribution at retirement, no gain or loss need
be recognized by the Partnership on a distribution of
property or money to a Partner (IRC Sec. 731(b)).
Likewise, no gain or loss need be recognized by the
Partner receiving the policy, regardless of whether the
value of the policy is higher or lower than the Partner’s
adjusted basis in the Partner’s interest in the Partnership
(IRC Sec. 731(a)).
Slide 20
Results for Jeremy Baker, Age 45, a Key Partner
of Baker, Simms, and Caldwell (“BS&C”)
(Partnership)
BS&C’s pre-retirement annual premium: $25,000
BS&C’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Jeremy’s services: $1,000,000
Portion allocated for survivor benefit for Jeremy’s family: $529,322
Jeremy’s pre-retirement survivor benefit: $100,000 yr. for 10 yrs.
Jeremy’s income tax when policy is transferred: $0
Jeremy’s policy withdrawal to pay the tax: N/A
Jeremy’s post-retirement annual premium: $0
Jeremy’s personal death benefit starting at age 65: $1,400,000+
Jeremy’s tax free retirement cash flow at age 65: $100,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 21
Executive Trifecta Illustrations
Taxation: Non-Shareholder Executive
C Corporation: At retirement, the policy is distributed to the
participating non-shareholder executive as compensation. The
executive has taxable income to the extent of the policy’s fair market
value -- which is generally approximated by the policy’s cash value
without reduction for surrender charges (IRS Rev. Proc. 2005-25).
Note: A non-shareholder executive of a C Corporation has identical
personal taxation as a non-owner executive of any other type of business.
In the year of policy distribution, the Corporation must recognize any
gain to the extent that the cash value of the policy exceeds the
Corporation’s premium payments; however, the Corporation is
entitled to a deduction under IRC Section 162 equal to the amount
the executive includes in income.
Slide 22
Results for Mark Fox, Age 45, a Key NonShareholder Executive of Ferris Metallurgical, Inc.
(C Corporation)
Ferris Metallurgical’s pre-retirement annual premium: $25,000
Ferris Metallurgical’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Mark’s services: $1,000,000
Portion allocated for survivor benefit for Mark’s family: $529,322
Mark’s pre-retirement survivor benefit: $100,000 a year for 10 years
Mark’s income tax when policy is transferred: $382,785
Mark’s policy withdrawal to pay the tax: $382,785
Mark’s post-retirement annual premium: $0
Mark’s personal death benefit starting at age 65: $1,000,000+
Mark’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 23
Executive Trifecta Illustrations
Taxation: Non-Shareholder Executive
S Corporation: At retirement, the policy is distributed to a
participating non-shareholder executive as compensation. The
executive has taxable income to the extent of the policy’s fair
market value -- which is generally approximated by the policy’s
cash value without reduction for surrender charges (IRS Rev.
Proc. 2005-25).
Note: A non-shareholder executive of an S Corporation has identical
personal taxation as a non-owner executive of any other type of business.
In the year of policy distribution, all shareholders are entitled to a
deduction equal to their proportionate share of the distributed
policy’s fair market value, and any gain will pass through to the
shareholders pro rata as ordinary income under the built-in gains
rules (IRC Secs. 311(b), 1366(a)(1) and 1374).
Slide 24
Results for Bruce Michaels, Age 45, a Key NonShareholder Executive of Advantis Software, Inc.
(S Corporation)
Advantis Software’s pre-retirement annual premium: $25,000
Advantis Software’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Bruce’s services: $1,000,000
Portion allocated for survivor benefit for Bruce’s family: $529,322
Bruce’s pre-retirement survivor benefit: $100,000 a year for 10 years
Bruce’s income tax when policy is transferred: $382,785
Bruce’s policy withdrawal to pay the tax: $382,785
Bruce’s post-retirement annual premium: $0
Bruce’s personal death benefit starting at age 65: $1,000,000+
Bruce’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 25
Executive Trifecta Illustrations
Taxation: Non-Member Executive
Limited Liability Company: At retirement, the policy is distributed
to the participating non-member executive as compensation. The
executive has taxable income to the extent of the policy’s fair market
value -- which is generally approximated by the policy’s cash value
without reduction for surrender charges (IRS Rev. Proc.2005-25).
Note: A non-member executive of a Limited Liability Company has identical
personal taxation as a non-owner executive of any other type of business.
In the year of policy distribution, all members are entitled to their
proportionate share of a deduction equal to the distributed policy’s
fair market value.
Slide 26
Results for Alan Johnson, Age 45, a Key NonMember of Scott Engineering, LLC
(Limited Liability Company)
Scott Engineering’s pre-retirement annual premium: $25,000
Scott Engineering’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Alan’s services: $1,000,000
Portion allocated for survivor benefit for Alan’s family: $529,322
Alan’s pre-retirement survivor benefit: $100,000 a year for 10 years
Alan’s income tax when policy is transferred: $382,785
Alan’s policy withdrawal to pay the tax: $382,785
Alan’s post-retirement annual premium: $0
Alan’s personal death benefit starting at age 65: $1,000,000+
Alan’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 27
Executive Trifecta Illustrations
Taxation: Non-Partner Executive
Partnership: At retirement, the he policy is distributed to a
participating non-partner executive as compensation. The
executive has taxable income to the extent of the policy’s fair
market value -- which is generally approximated by the policy’s
cash value without reduction for surrender charges (IRS Rev.
Proc.2005-25).
Note: A non-partner executive of a Partnership has identical personal
taxation as a non-owner executive of any other type of business.
In the year of policy distribution, all partners are entitled to their
proportionate share of a deduction equal to the distributed
policy’s fair market value.
Slide 28
Results for Ted Coombs, Age 45, a Key NonPartner of Baker, Simms, and Caldwell (“BS&C”)
(Partnership)
BS&C’s pre-retirement annual premium: $25,000
BS&C’s pre-retirement death benefit: $1,529,322
Portion allocated for loss of Ted’s services: $1,000,000
Portion allocated for survivor benefit for Ted’s family: $529,322
Ted’s pre-retirement survivor benefit: $100,000 a year for 10 years
Ted’s income tax when policy is transferred: $382,785
Ted’s policy withdrawal to pay the tax: $382,785
Ted’s post-retirement annual premium: $0
Ted’s personal death benefit starting at age 65: $1,000,000+
Ted’s tax free retirement cash flow at age 65: $61,000 for 20 yrs.
Click here
to review the illustration.
Main Menu ->
Slide 29
Tax Notes
Click here
to review Tax Notes regarding:
Tax details of the plan for various business entities (C Corp,
S Corp., LLC, Partnership) based on a participant’s relationship
to those entities;
Suitability of the plan based on the type and size of a business.
Note: Transfer taxation for shareholders of an S Corporation is
different based on the number of shareholders participating in the
plan. Be sure to review Sections 2a, 2b, and 2c of the Tax Notes
file for details (including the Notes that follow Section 2c).
Main Menu ->
Slide 30
Excess Compensation
Shareholder Executive of a C Corporation: Executive Trifecta can
produce substantial cash values for this participant at the point the
policy is transferred to the executive. Such sums should not
necessarily trigger excess compensation because the agreement to
transfer would likely have been in effect for many years and
therefore covers many years of service. A client’s legal and tax
counsel should be specifically consulted on this issue.
Excess compensation should not an issue for pass-through entities
such as S Corporations, Limited Liability Companies, and
Partnerships.
Slide 31
Policy Death Benefit
Prior to the distribution of the policy to the insured participant, the
entire death benefit of the policy funding an Executive Trifecta
arrangement is payable to the business entity in order to provide it
with funds to 1) indemnify the business against the loss of services
of the insured participant and 2) informally fund the payment of a
Survivor Income Benefit to the insured participant’s family.
The policy death benefit received should be income tax free to the
business entity under IRC Section 101(a) provided that the
appropriate notice and consent documents have been executed as
required by IRC Section 101(j)(4) as well as the reporting
requirements required by IRC Section 6039I.
Slide 32
Policy Death Benefit
(continued)
The notice and consent requirements of IRC Sec. 101(j)(4) are
met if, before the life insurance policy is issued, the employee:
is notified in writing that the employer intends to insure the
employee’s life and the maximum face amount of the coverage
at the time the coverage is issued;
gives written consent to being insured under the contract and
continuation of such coverage after the insured employee
terminates employment; and
is informed in writing that the employer will be a beneficiary of
death proceeds from the policy.
Slide 33
Policy Death Benefit
(continued)
With respect to IRC Section 6039I, an employer that, after August
17, 2006, has one or more employer-owned life insurance contracts
must file a return that shows for each year the policy is owned:
the number of employees employed at the end of the year;
the number of employees insured under employer-owned life
insurance contracts at the end of the year;
the total amount of insurance in force under such contracts at the
end of the year;
the name, address, and taxpayer identification number of the
employer and the type of business in which the employer is
engaged; and
that the employer has a valid consent for each insured employee.
Slide 34
Policy Death Benefit
(continued)
Record Keeping Requirement – Any employer (or other applicable
policyholder) that owns one or more employer-owned life insurance
contracts during the year must keep whatever records are
necessary to determine whether the requirements of the IRC
Sections 6039I and 101(j) are met.:
A specimen “Company-Owned Life Insurance - Notice and Consent
Form” (as required by IRC Section 101(j)) and a specimen
“Company-Owned Life Insurance - Annual Reporting Form” (as
required by IRC Section 6039I) are in the Executive Trifecta
document set and in the Special Files section of InsMark’s
Documents On A Disk and Documents On The Net Systems
(Versions 17.0 and higher).
Slide 35
Policy Death Benefit
(continued)
Regardless of the business entity, the Survivor Income Benefit paid
to an insured participant’s family when the insured dies prior to
distribution of the policy should be deductible by the business when
paid (IRC Sec. 404(a)(5)) and taxable as ordinary income to the
recipient(s). The survivor benefits are subject to tests of reasonable
compensation (IRC Sec. 162).
Note re Shareholders of S Corporations, Members of Limited
Liability Companies, and Partners of Partnerships: Legal and tax
advisers may find it advantageous to treat the death benefit
proceeds allocated for the survivor income benefit as a lump sum
K-1 distribution.
Slide 36
Policy Death Benefit
(continued)
After the policy is transferred to the insured (typically at retirement),
any subsequent death benefit payable to that participant’s
beneficiaries should be income tax free under IRC Section 101(a).
Slide 37
Retirement Cash Flow
After policy ownership is transferred to the insured (typically at
retirement), any withdrawals of cash values or dividends from the
policy by the participant should be income tax free to the extent
they do not exceed the insured’s basis. Any policy loans should
also be income tax free (provided the policy stays in force).
Slide 38
Illustration Resources
Licensees for Version 15.0 (and higher) of the InsMark
Illustration System can review all the menu input for the
Executive Trifecta illustrations in this presentation by double
clicking on the file named Executive Trifecta (PPT).!II located
in the following directory of your computer:
C:/insmark/workbook
Close this presentation before launching that file.
If you are not licensed for the InsMark Illustration System, call
InsMark at 1-888-InsMark (467-6275) for licensing information.
Slide 39
Specimen Documentation
Specimen documentation for Executive Trifecta can be found in Version
17.0 of InsMark’s Documents On A Disk® (“DOD”) System and Documents
On The Net® System (“DON”).
The InsMark Illustration System has a link to these documents on the lower
right side of the Workbook window (when in Edit mode in the Executive
Trifecta module).
Version 18.0 of DOD and DON (due for release in the 2nd Quarter of 2008)
has more comprehensive documentation for S Corporations, Limited
Liability Companies, and Partnerships. If you are a user authorized to
receive Version 18.0 and would like copies of such documentation prior to
the release, contact InsMark at 1-888-InsMark (467-6275).
If you are not licensed for either DOD or DON, call InsMark at 1-888InsMark (467-6275) for licensing information.
Slide 40
IRC Section 409A
Executive Trifecta falls under the purview of IRC Section 409A;
however, provided the plan is properly designed, documented,
and administered, there should be no adverse affects relative
to Sec. 409A that should apply.
Executive Trifecta works because, even though it may fail the
substantial risk of forfeiture test and be characterized as
deferred compensation under IRC Section 409A, it meets the
election and distribution requirements of Section 409A, thus
allowing for deferral of income.
Slide 41
IRC Section 409A
(continued)
Under the regulations, it appears that a plan may fail to have a
substantial risk of forfeiture under Section 409A but have a
substantial risk of forfeiture under IRC Section 83, thus being
deferred compensation for income tax purposes but a welfare
plan for ERISA purposes.
Unless the IRS provides future guidance to the contrary,
Executive Trifecta would be deemed to have a substantial risk
of forfeiture for Section 83 and ERISA purposes, and the plan
would meet the deferred compensation requirements of
Section 409A.
Slide 42
Sarbanes-Oxley Act
Since Executive Trifecta does not involve loan funding of premiums,
it is unaffected by the provisions of Sarbanes-Oxley that prohibit
loan-based split dollar. Consequently, it is available for executives of
publicly-owned companies as well as private ones.
Split Dollar
Executive Trifecta has no split dollar features and should be
unaffected by the U. S. Treasury Department’s Final Split Dollar
Regulations issued in September 2003.
Slide 43
Suitability - Type of Business
C Corporation: A C Corporation can retain its net profits as
operating capital or merely to strengthen the balance sheet;
however, a C Corporation is taxed at the corporate level on net
profits. If net profits are then distributed as dividends, the
shareholder(s) are again taxed. If all net after tax profits are
distributed, there are no funds left to provide the Executive
Trifecta for anyone, and it is unlikely that such a C Corporation
can utilize Executive Trifecta.
The ideal C Corporation candidate for Executive Trifecta is one
that requires a strong balance sheet and therefore retains a
portion of net profits.
Slide 44
Suitability - Type of Business
(continued)
S Corporation, Limited Liability Company, Partnership:
These pass-through entities, like C Corporations, can decide to
retain net profits as operating capital or merely to strengthen
the balance sheet. However, all profits are considered as if
they were distributed to shareholders, members, or partners,
as the case may be, and are income taxable to those
individuals. As a result, most pass-through entities distribute at
least an amount of net profits to cover the income tax. If the
remaining net profits are also distributed, there are no funds
left to provide the Executive Trifecta benefit for anyone.
The ideal pass-through entity candidate for Executive Trifecta
is one that retains a portion of net profits.
Slide 45
Suitability - Size of Business
With standard deferred compensation arrangements, there
may be a concern that a business may not survive the death of
its owner(s) resulting in an absence of the continuity of
management needed to fulfill retirement income commitments.
With Executive Trifecta, the policy values that fund the insured
participant’s retirement cash flow are generated from a life
insurance policy that has been contractually transferred to that
participant, and the continuation of the business thereafter is
irrelevant to that cash flow.
Slide 46
Suitability - Size of Business
(continued)
Continuity of management concerns can be avoided with the
survivor income benefit associated with Executive Trifecta by
scheduling the payment to the insured’s family in a lump sum.
Note: Legal and tax advisers may find it advantageous to treat
the death benefit proceeds allocated for the survivor income
benefit as a lump sum K-1 distribution for principals of S
Corporations, Limited Liability Companies, and Partnerships.)
Slide 47
Important Notice
Examples and case studies are for illustration purposes.
Actual results may vary. Legal and tax information is for
general use only and may not be applicable to specific
circumstances. Clients should consult their own legal, tax
and accounting advisors to assist in the evaluation of any
potential transaction or strategy.
Policy loans reduce policy cash values and death benefits,
and the lapse of a loaned policy could result in severe tax
ramifications to the policy owner. Be sure to consult a
professional tax adviser if you have questions about this.
Slide 48
Circular 230 Disclosure
In order to ensure compliance with requirements imposed by
the IRS under Circular 230, any U.S. Federal tax advice or
information contained in this communication is not intended or
written to be used, and cannot be used, for the purpose of
(1) avoiding penalties under the Internal Revenue Code or
(2) promoting, marketing or recommending to another party
any matters addressed herein.
Slide 49
Circular 230 Disclosure
(continued)
In the event that this document (including any attachments,
enclosures, or referred material) is also considered to be a
“marketed opinion” within the meaning of the IRS guidance,
then, as required by the IRS, please be further advised that
the material contained herein is written to support the
promotions or marketing of the transactions or matters
addressed by the material contained herein, and, based on
the particular circumstances, you should seek advice from an
independent tax adviser.
Slide 50
“InsMark”, “Executive Trifecta”, and “Documents On A Disk”
are registered trademarks of InsMark, Inc.
Click here
for the Main Menu.
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to start from the beginning.
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to end this presentation.
Clip art may not be reused without written authorization from its owner.
Copyright 2006-2008, InsMark, Inc.
All Rights Reserved