Under paragraph (e)(4)(iii)(B)(2) of this section, the first loan is treated as retired at the end of year 5 and a new 5-year split-dollar term loan is issued at that time, with interest payable at 10 percent. If the borrower (or lender) does or does not exercise the option as projected under paragraph (e)(4)(iii)(B)(1) of this section, the split-dollar loan is treated for purposes of https://www.virginiaindependent.com/uncategorized/operations-management-what-it-is-and-how-it-works/ this section as retired and reissued on the date the option is or is not exercised for an amount of cash equal to the loan’s adjusted issue price on that date. For purposes of determining a split-dollar loan’s term, the borrower is projected to exercise or not exercise an option or combination of options in a manner that minimizes the loan’s overall yield. However, this paragraph (e)(4)(iii)(B)(1) applies only if the timing and amounts of the payments that comprise each payment schedule are known as of the issue date.
(i) The facts are the same as in Example 1 except that, upon termination of the arrangement or E’s death, R is entitled to receive the lesser of the aggregate premiums or the policy cash value of the contract. Because R pays all the premiums on the life insurance contract, R provides to E the entire amount of the current life insurance protection E receives under the arrangement. (ii) Because R is designated as the policy owner of the contract, R is the owner of the contract under paragraph (c)(1)(i) of this section. Upon termination of the arrangement or E’s death, R is entitled to receive the greater of the aggregate premiums or the policy cash value of the contract. (ii) The amount of all economic benefits described in paragraphs (d)(2)(ii) and (iii) of this section actually taken into account by the non-owner (and the owner for gift tax and employment tax purposes) plus any consideration described in paragraph (d)(1) of this section paid by the non-owner for such economic benefits described in paragraphs (d)(2)(ii) and (iii) of this section.
As under the 2002 proposed regulations, ownership of the life insurance contract determines which regime applies. The 2002 proposed regulations reserved on the rules for valuing economic benefits provided to the non-owner under an equity split-dollar life insurance arrangement governed by the economic benefit regime, pending receipt of comments from interested parties. Final regulations under section 61 of the Code provide comprehensive guidance on the federal tax treatment of split-dollar life insurance arrangements.
Can periodic sentences become too long or complex?
For year 1, E is also provided, under paragraph (d)(2)(i) of this section, current life insurance protection of $1,445,000 ($1,500,000 minus $55,000 payable to R). (A) To which, under the arrangement, the non-owner has a current or future right; and The term self-employment tax means the tax imposed by the Self-Employment Contributions Act of 1954 (SECA). The term employment tax means any tax imposed by, or collected under, the Federal Insurance Contributions Act (FICA), the Federal Unemployment Tax Act (FUTA), the Railroad Retirement Tax Act (RRTA), and the Collection of Income Tax at Source on Wages.
Each of the deemed loans has the same terms and conditions as the original loan. A’s net investment income for 2009 is $1,100, and there are no other outstanding loans between A and B. The payment is a below-market split-dollar demand loan. For purposes of section 163(d), the imputed interest from the indirect participant to the lender that is taken into account by the indirect participant under this paragraph (e)(2) is not investment interest to the extent of the excess, if any, of— For loan arrangements between husband and wife, see section 7872(f)(7). See paragraph (f) of this section for the treatment of any stated interest or OID on split-dollar loans.
How Stephen King’s Writing Guide Changed My Creative Life
Loose sentences focus on clarity and logic. Periodic sentences are not what is a periodic sentence just literary devices – they can be used for emphasis and flair in everyday communication. Periodic sentences add welcome variety alongside loose and cumulative structures, enhancing flow and rhythm.
Demonstrative Pronouns: Definition and Examples
- Repayment of both the premium payment and the interest due thereon is nonrecourse to F.
- Redesignating paragraphs (d)(2) (ii)(a) and (b) as paragraphs (d)(2)(ii)(A) and (B), respectively.
- Employee B issues a 10-year split-dollar term loan to Employer Y.
- This philosophic line exemplifies Shakespeare’s penchant for periodic structure in his pithy, impactful phrases.
- E directs the insurance company to use the $500 as E’s premium payment for year 5.
(i) The facts are the same as in Example 1 except that in year 5, R and E modify the split-dollar life insurance arrangement to provide that, upon termination of the arrangement or E’s death, R is entitled to receive the greater of the aggregate premiums or one-half the policy cash value of the contract. After the transfer of an undivided interest in a life insurance contract (or, if later, at the time such transfer is taxable under section 83), the person who previously had been the non-owner is treated as the owner of a separate contract consisting of that interest for all purposes, including for purposes of paragraph (b) of this section and for purposes of §1.61-2(d)(2)(ii)(A). Any premium paid by an owner under a split-dollar life insurance arrangement subject to the rules of paragraphs (d) through (g) of this section is included in the owner’s investment in the contract under section 72(e)(6). A split-dollar life insurance arrangement is any arrangement between an owner and a non-owner of a life insurance contract that satisfies the following criteria—
- Thus, under paragraph (d)(4)(ii) of this section, E has current access to such portion of the policy cash value for each year that the arrangement is in effect.
- The transferor of the life insurance contract must fully take into account all economic benefits provided under the split-dollar life insurance arrangement.
- (i) On July 1, 2009, Corporation Z and Shareholder A enter into a split-dollar life insurance arrangement under which A is named as the policy owner.
- Periodic sentences are often viewed as more literary and formal.
- (E) A change solely to the ministerial provisions of the life insurance contract (for example, a change in the address to send payment);
- Like the periodic sentence, cumulative sentences are usually complex sentences.
- See paragraph (g) of this section and §1.83-6(a)(5) for tax consequences upon the transfer of the contract (or an undivided interest therein).
See §1.61-22(b)(6) for the treatment of amounts other than interest on a split-dollar loan that are waived, cancelled, or forgiven by the lender. However, the parties made a representation under paragraph (d)(2) of this section. Repayment of both the premium payment and the interest due thereon is nonrecourse to F. On January 1, 2010, V makes a $100,000 premium payment, repayable in 15 years. (3) Testing for sufficient interest—(i) Demand loan. (2) Term, payment schedule, and yield.
Periodic Sentences
This structure creates suspense or interest as the reader waits to find out the main point of the sentence. This special type of sentence structure holds the key to making your writing more engaging and memorable. Have you ever read a sentence that kept you on the edge of your seat until the very end? In this case, adjusting some periodic structures to loose ones achieves nimble variation with less potential to divert the reader’s attention. While not necessarily a poorly written paragraph, it does begin to build a monotony that would benefit from revision. To reach the core thought, we have to read all the way to the end—i.e., to the period (periodic).
The periodic style encapsulates both the tone and themes of the story. Jane Austen utilized periodic phrasing masterfully in her novels. This sentence immerses readers into the contradictory setting of late 18th-century England and France. Balanced and periodic structures both utilize rhythm but differ in main idea placement. A balanced sentence presents two ideas of equal weight in parallel, using repetition. A cumulative sentence begins with the main idea and then expands with phrases and clauses.
(ii) Commencing in year 7 (and in each subsequent year), E must include in gross income the economic benefits described in paragraph (d)(2)(ii) of this section as provided in this Example 4(ii) rather than as provided in Example 2(ii). (iii) The arrangement is not described in paragraph (c)(1)(ii)(A)(1) of this section after it is modified in year 5. Thus, in year 5 (and each subsequent year), E must also include in gross income under paragraph (d)(1) of this section the value of the economic benefits described in paragraph (d)(2)(ii) of this section provided to E in each year. Thus, under paragraph (d)(4)(ii) of this section, E has current access to such portion of the policy cash value.
This document contains final regulations relating to the income, employment, and gift taxation of split-dollar life insurance arrangements. Under the loan regime, the non-owner of the life insurance contract is treated as loaning premium payments to the owner of the contract. Any amount received by a lender under a life insurance contract that is part of a split-dollar life insurance arrangement is treated as though the amount had been paid to the borrower and then paid by the borrower to the lender. (4) Any other payment with respect to a split-dollar life insurance arrangement, other than a payment taken into account under paragraphs (k)(1), (2), and (3) of this section. (3) A payment of amounts previously paid by a non-owner pursuant to a split-dollar life insurance arrangement that were not reasonably expected to be repaid by the owner; and (i) On January 1, 2010, Employer T and Employee G enter into a split-dollar life insurance arrangement under which G is named as the policy owner.
By delaying the most important information, periodic sentences further underscore the central idea, often creating emphasis, suspense, or surprise. We’ll begin our review of periodic sentences by first looking at how they differ from loose sentences. According to Merriam-Webster, the linguistic sense of the periodic sentence term was coined circa 1928, but there is evidence of its usage in a separate sense dating from 1766. A periodic sentence, on the contrary, positions the important information at the end. The periodic sentence has become much rarer in formal English writing over the past hundred years, and it has never been common in informal spoken English (outside of bad political speeches). When a periodic sentence winds through clauses like a mountain road delaying its destination, it exploits this cognitive vulnerability with surgical precision.
(1) If, immediately after such modification, the employer, service recipient, or donor is the owner of the life insurance contract under the split-dollar life insurance arrangement (determined without regard to paragraph (c)(1)(ii)(A) of this section), the employer, service recipient, or donor continues to be treated as the owner of the life insurance contract. Similarly, for estate tax purposes, regardless of who is treated as the owner https://washing.uio.com.tw/what-are-adjusting-entries-definition-types-and-2/ of a life insurance contract under the final regulations, the inclusion of the policy proceeds in a decedent’s gross estate will continue to be determined under section 2042. As discussed earlier, the final regulations treat the donor as the owner of a life insurance contract where the donee is named as the policy owner if, under the split-dollar life insurance arrangement, the only economic benefit provided to the donee by the donor under the arrangement is the value of current life insurance protection.
(5) Special rules for certain split-dollar term loans—(i) In general. (iii) In accordance with section 7872(b)(1) and paragraph (e)(4)(iv) of this section, on the date that the loan is made, Z is treated as transferring to A $63,755.40 (the excess of $100,000 (amount loaned) over $36,244.60 (imputed loan amount)). This loan is a below-market split-dollar term loan because the imputed loan amount of https://creator-nutrition.com/cost-variance-cost-variance-analysis-what-it-is/ $36,244.60 (the present value of the amount required to be repaid to Z) is less than the amount loaned ($100,000).
