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As a result, the deemed-allocation rules (which automatically allocate a transferor's GST exemption to direct skips and lifetime indirect-skip transfers) apply to split gift transfers as well.
Our position is that if someone thinks the IRS closed the door on split dollar, shared ownership will open the window," she added.
The company hit an earnings bump and McNamee admits Hooper Holmes shareholders are not getting the full return on the split.
Back in December, Cortex Pharmaceuticals, a company with a shallow coffer of capital, announced a one-for-five reverse stock split.
At first glance, split dollar might not seem like such a good deal for an employer.
Both spouses must consent to split the gifts; consent is signified only by filing and signing Form 709, U.