This memorandum discusses a proposal regarding split-dollar insurance arrangements involving Leon Black, AIF IV Management Inc., and Norman Brownstein, the trustee of the 1999 Life Insurance Trusts. It outlines the background of the insurance policies, the financial obligations of AIF, and the proposed restructuring of the arrangements to minimize tax consequences. The proposal includes the acquisition of rights under the split-dollar agreements by the Black 2006 Family Trust and the repayment of loans to Black Family Partners.
documents/EFTA00585076.pdf
{}