1. If, immediately after this change, the employer, beneficiary or donor is the owner of the life insurance contract under the life insurance agreement (excluding paragraph c) (1) (1) (1) (A) of this section), the employer, beneficiary or donor is still considered the owner of the life insurance contract. (D) the date on which the parties to the agreement reach a political agreement; in 2001 and 2002, the IRS published submissions on the 2001 and 2002 agreements on the 2001 and 2002 agreements, which provide further clarification on how the IRS was considering taxing the 2010 dollar agreements. The second of these notices, Communication 2002-8 (which cancelled the 2001 communication), was issued on 28 January 2002 and announced the IRS` intention to publish new rules that would codify a comprehensive approach to the taxation of life insurance in separate dollars on the basis of two mutually exclusive tax systems. The proposed regulations were published at the end of 2002, but final regulations have not yet been published. Unfortunately, the approaches announced in the proposed notice and regulations are at odds with much of the widely accepted tax theory on which most existing dollar splitting plans are based. In a typical dollar split agreement, the employer pays all or most of the policy premiums in exchange for a contribution to the value of the insurance and the death allowance. In the past, the IRS has defended the position that the insured employee must recognize the “termcost” of life insurance coverage as income. The “cost of living” is the cost of a one-year policy for the insured worker with the same death benefit, that is, what it would cost the worker to purchase the same insurance coverage for one year under a term policy.2 In some agreements, the worker actually pays the appointment fee. Futures costs are generally quite low until a person reaches an advanced age, and are generally significantly lower than the actual premiums paid for the policy.
The Finanzgericht rejected also the counter-arguments of the succession.