Thursday, November 12, 2026
  • Login
Subscribe
Impact Wealth
No Result
View All Result
  • Lifestyle
    • Health & Wellness
    • Fine Dining & Beverage
    • Fashion
    • Event Coverage
    • The Arts
    • Resources
  • Travel
  • Investing
    • Retirement
    • Real Estate
    • Philanthropy
    • Wealth
    • Business
  • Family Office News
  • Impact Interviews
  • Subscribe Now
  • About Us
    • Press
  • Join Our Community
  • Sign up for Newsletter
  • Lifestyle
    • Health & Wellness
    • Fine Dining & Beverage
    • Fashion
    • Event Coverage
    • The Arts
    • Resources
  • Travel
  • Investing
    • Retirement
    • Real Estate
    • Philanthropy
    • Wealth
    • Business
  • Family Office News
  • Impact Interviews
  • Subscribe Now
  • About Us
    • Press
  • Join Our Community
  • Sign up for Newsletter
No Result
View All Result
Impact Wealth
No Result
View All Result
Home Wealth

Split Dollar: The Powerful Estate Tax Mitigation Strategy Not Discussed Often Enough

by Angela Gorman
August 31, 2026
in Wealth
Split Dollar

Updated posts August 2026

Under the current Unified Estate & Gift Tax Credit of $12,920,000 per individual expiring at the end of 2025 and a new estimated reduction of $6 Million per individual, many Americans now find themselves reevaluating their estate plans. Given that this is a “use-it-or-lose-it” situation, one fact has become crystal clear: one should absolutely be taking advantage of this lifetime exemption.

But what comes after you’ve already used all of the exemption and commonly used estate planning strategies, such as Grantor Retained Annuity Trusts and sales to irrevocable trusts, only to hit a roadblock? In truth, all of these legacy planning techniques come with their own set of issues.

Split Dollar

The Power of Split Dollar in Intergenerational Wealth Preservation

With GRATs, the estate tax problem is simply transferred to the children who possess their own sizable estates, with prior family gifting offering no intergenerational wealth preservation benefits. If a person engages in a sale of assets to a family trust, a highly effective estate freezing technique, but retains a note, that note is includable in their estate for around 70 percent of the sold asset’s appraised value.

However, if you find yourself in the small percentage of those who have used their lifetime exemption, executed all of the common planning techniques, and still have sizable estate tax exposure at your own or your children’s generational level, then you might want to consider a strategic life insurance arrangement commonly referred to as Intergenerational Split Dollar.

What Is a Split Dollar Arrangement and How Does It Work?

It’s important to note that the Split Dollar Arrangement is not a type of insurance, but rather an approach to funding a life insurance policy and sharing, or splitting, the proceeds at the insured’s time of death. As defined by Treasury Regulation Section 1.61-22(b), the strategy is an arrangement between an owner and a non-owner of a life insurance contract, in which a third party serves as a donor of the premium and is thereby entitled to recover and secure those premiums in the form of proceeds from the life insurance contract.

Understanding the Split Dollar Note in Estate Planning

The Donor, or Grantor, then maintains the right to be repaid the greater of the cash value or the aggregate premiums paid, referred to as the right of reimbursement, typically paid upon death unless the agreement is terminated by mutual consent of the Donor and the trust or trustee, as outlined in the Split Split Dollar Regulations of 2003. For ease of understanding, experts refer to this as the Split Dollar Note, or simply the note.

Leveraging the Appraised Value in Split Dollar Estate Planning

The note can be transferred by the Donor into another trust through a sale, gift, or some combination of the two, at an appraised value. Recent court guidance suggests that, at the time of transfer, the economic value of the note can be substantially lower than the principal and accrued interest, presenting an additional estate planning opportunity. Since the note accrues all interest and is not payable by the Grantor Trust to the Grantor until after the death of the insured, appraisal of the note may be valued at a substantial discount of 70 to 80 percent.

Eliminating Estate Taxes with Intergenerational Split Dollar

The end result is that one can dramatically reduce or eliminate gift, estate, and generation-skipping transfer taxes on intergenerational wealth transfers where the client has a genuine desire to benefit the next generation and beyond. Targeted assets can be income or non-income real estate, company stock, securities, and even art. Taxable QTIP assets and completed

Utilizing Split Dollar for Diverse Asset Transfers

GRAT assets can be transferred into a non-taxable Dynasty Trust for generations, as well as providing an excellent solution for moving notes out of one’s estate from completed sales to irrevocable trusts. Thanks to recent tax court cases, litigation has provided a clear and discernible roadmap of acceptable circumstances and fact patterns for Split Dollar planning, and has provided an opportunity for many ultra-high-net-worth families to further accomplish intergenerational wealth planning, saving them tens to hundreds of millions of dollars in estate taxes.

Why Timing Matters More Than Ever

What makes this strategy especially relevant right now is the ticking clock on the current exemption itself. With the lifetime exemption set to roughly halve at the end of 2025, families sitting on assets that could still benefit from a Split Dollar arrangement have a narrowing window to lock in today’s more favorable discount opportunities before the underlying tax landscape shifts substantially.

About: Norton Advisory Group, a Member of PH Robb Legacy Alliance, is a boutique insurance consulting firm with a strong emphasis on estate planning and tax mitigation. For more information on advisory and other services, please contact Irene Norton at Irene@nortonadvisorygroup.com.

NORTONADVISORYGROUP.COM

Tags: advisoryboutiqueconsultingdynastyestatefinancesinsurancepolicyinterestintergenerationalwealthlegacylifeinsurancemoneynetworthnortonadvisorygroupplanningriskmanagementsalessplitdollarnotestockstaxestaxmitigationtaxpayerstrusts
Previous Post

Haute Couture 2023: Where Fashion Meets Dreams

Next Post

The Enigmatic Karakoram Highway: A Journey into the ‘Eighth World Wonder

Related Posts

Asset Management Firms Worth Considering for Alternative Investments in Volatile Markets
Investing

Asset Management Firms Worth Considering for Alternative Investments in Volatile Markets

November 11, 2026
What to Check Before Using AI in Family Wealth Meetings
Family Office

What to Check Before Using AI in Family Wealth Meetings

November 9, 2026
Gold and Silver in Your Retirement Mix: A Wealth-Preservation Guide
Investing

Gold and Silver in Your Retirement Mix: A Wealth-Preservation Guide

November 9, 2026
Jordan Welch, entrepreneur and founder of Viral Vault
Net Worth

Jordan Welch Net Worth 2026: Our $6M Estimate After Viral Vault

November 4, 2026
single-vs-multi-family-office-cost
Wealth Management

After California’s Billionaire Tax Vote: Where Wealthy Residents Could Go Next

November 6, 2026
Thach Nguyen, Seattle real estate investor and founder of Thach Real Estate Group
Net Worth

Thach Nguyen Net Worth 2026: Our $15M Estimate vs. His $100M Portfolio

November 3, 2026
Next Post
Karakoram Highway

The Enigmatic Karakoram Highway: A Journey into the 'Eighth World Wonder

No Result
View All Result

Latest Stories

anthropic-ipo-wealthy-investors-guide

Anthropic IPO for Wealthy Investors: Allocation, Sizing and Lock-Up Planning

Read More »
Asset Management Firms Worth Considering for Alternative Investments in Volatile Markets

Asset Management Firms Worth Considering for Alternative Investments in Volatile Markets

Read More »
Farmer Family Donation Miami University Farmer School of Business

Farmer Family Foundation Plans Up to $100 Million for Miami University

Read More »
What Modern Due Diligence Overlooks Before Big Deals

What Modern Due Diligence Overlooks Before Big Deals

Read More »
Impact Wealth Magazine

Impact Wealth is a luxury lifestyle magazine that caters to ultra-high net-worth individuals and the family office industry that features profiles on the world’s top business leaders and family offices, and investment strategies for the super rich.

Explore

  • Wealth
  • Net Worth
  • Investing
  • Family Office
  • Real Estate
  • Impact Investing
  • Philanthropy
  • Travel Lifestyle
  • Impact Leaders
  • Interviews

About Impact Wealth

  • Press
  • About Impact Wealth
  • Past Issues
  • Resources
  • Editorial Standards and Corrections

Stay Connected

Join Our Community

Sign up for our Newsletter

© 2026 ImpactWealth | Disclaimer & Privacy Policy

No Result
View All Result
  • Lifestyle
    • Health & Wellness
    • Fine Dining & Beverage
    • Fashion
    • Event Coverage
    • The Arts
    • Resources
  • Travel
  • Investing
    • Retirement
    • Real Estate
    • Philanthropy
    • Wealth
    • Business
  • Family Office News
  • Impact Interviews
  • Subscribe Now
  • About Us
    • Press
  • Join Our Community
  • Sign up for Newsletter

© 2026 ImpactWealth | Disclaimer & Privacy Policy

Welcome Back!

Login to your account below

Forgotten Password?

Retrieve your password

Please enter your username or email address to reset your password.

Log In
No Result
View All Result
  • Lifestyle
    • Health & Wellness
    • Fine Dining & Beverage
    • Fashion
    • Event Coverage
    • The Arts
    • Resources
  • Travel
  • Investing
    • Retirement
    • Real Estate
    • Philanthropy
    • Wealth
    • Business
  • Family Office News
  • Impact Interviews
  • Subscribe Now
  • About Us
    • Press
  • Join Our Community
  • Sign up for Newsletter

© 2026 ImpactWealth | Disclaimer & Privacy Policy