This memorandum provides a summary of the history and status of split dollar insurance arrangements involving Leon D. Black. It discusses the background of the insurance trusts created in 1999, the rationale for implementing a split dollar insurance plan, and the various proposals to unwind these agreements. The document outlines the financial implications, tax considerations, and potential risks associated with each proposal. It also includes a comparison of different proposals to roll-out the agreements, highlighting the pros and cons of each approach.
documents/EFTA00619894.pdf
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