Webinar

Management Company ESOP Structures and the Insurable Interest Doctrine

Policy compliant management company C or S corporation ESOP structures offer several advantages when cast in a Section 409(p) policy compliant economically substantive succession plan. As it turns out, Section 409(p) policy compliance coalesces insurable interest doctrine policy considerations. The result proves awesome. Extant life insurance policy cash values and future life insurance premiums effectively transform into pre-tax costs while the death benefit remains tax-free. This paper explains.

Syllabus

Lesson 1.

Introduction

Lesson 2.

C versus S Corporation Leveraged ESOP Distinctions

Lesson 3.

The Management Company C and S Corporation ESOP Structure

Lesson 4

Life Insurance Funded Economically Substantive Succession Planning Management Company ESOP Structures

Lesson 5.

The Insurable Interest Doctrine    

Lesson 6

Conclusion

Objectives

*Recognize retirement plan characteristics that correctly distinguish ESOPs from all other retirement plans  

*Recognize Professor Simons’ Four Levers and the Balanced Scorecard’s Four Perspectives correctly distinguish the Economically Substantive Succession Planning Four Stages  

*Recognize the Section 409(p) impounded economically substantive succession planning policy compliance conclusive presumption is an affirmative defense to Section 404(k)(5)(A) substance over form IRS C corporation reasonable applicable dividend challenges  

*Recognize Section 409(p) impounded economically substantive succession planning policy compliance and insurable interest doctrine policy compliance correctly occupy the same Four Stages space when measured against the limits of the entrepreneur’s semi-retirement, complete retirement, and physical life

Highlights

*General Employee Stock Ownership Plan (ESOP) characteristics    

*Hierarchical quaternary order economically substantive succession planning management control system strategies and definitions:  The Entrepreneurial Stage, The Protectionist Stage, The Separate Entity Stage, & The Social Policy Stage

*Section 409(p) economically substantive succession planning policy continues contributions to America’s productivity beyond the limits of the entrepreneur’s semi-retirement, complete retirement, or physical life  

*C and S corporation leveraged ESOP distinctions  

*Reasonable C corporation leveraged ESOP loan repayment applicable dividends and the Section 409(p) impounded economically substantive succession planning policy compliance conclusive presumption affirmative defense  

*The insurable interest doctrine  

*Coalescing Section 409(p) impounded economically substantive succession planning and insurable interest public policies

Additional Information

Designed For

*CPAs
*Attorneys
*Enrolled Agents
*Enrolled Retirement Plan Agents
*Self-directed Retirement Plan Fiduciaries, Custodians, and Administrators
*Self-directed Retirement Plan Account Holders
*Tax Return Preparers

Vendor

ACPEN

Advanced Preparation

None

Prerequisite

This webcast is an intermediate continuing education webcast.
It is assumed the webcast participant has achieved the following related webcasts in advance of this webcast: Retirement Plan Management and Investment Risk Diversification Standards, Management and Investment Risk Diversification Indices, Prohibited Transaction Chinese Walls, Problematic Self-Directed Retirement Plan Activities, Changing ERISA's Disqualified Person Criterion, Got Your Assets Covered, Resolving the Passive Custodian Paradox, Section 409(p)'s Economically Substantive Succession Planning Policy Implications

Field of Study

Taxes

Course Number

171239892

Level of Knowledge

Intermediate

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