Copyright © 2019 TRC Financial. All rights reserved.

TRC Financial Insurance Services and affiliates are presently licensed to sell insurance and annuity products, as well as other securities products in the following states: Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Idaho, Illinois, Iowa, Kansas, Kentucky, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nevada, New Jersey, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Washington, West Virginia and Wisconsin. Residents of other states should consult with a local registered representative for insurance services and securities products. Proper state registration is mandatory prior to conducting business in that state. This is not an offer to sell securities, which may be done only after proper delivery of a prospectus and a client suitability review. CA License - #0E14614 \ CA License #0B40789 \ CA License #0B52893 - The principle place of business and the state of domicile for TRC Financial is: 1 Post, Suite 150, Irvine, CA 92618. Securities offered through Registered Representatives of M Holdings Securities, Inc., a Registered Broker/Dealer Member FINRA / SIPC. Check the background of this Firm and/or investment professional on FINRA's BrokerCheck. TRC Financial is independently owned and operated and is a Member Firm of M Financial Group. Please go to www.mfin.com and click on “Disclosure Statement” at the bottom of the home page for further details regarding this relationship.

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IRS Rules on Tax Effects of Transfers by Two Banks of BOLI Policies to New LLC

April 13, 2012

 

In PLR 201152014, the Revenue Service ruled on the consequences to two banks that contributed both separate account and general account “BOLI” policies to an LLC in exchange for membership interests. The IRS first determined that the transfers to the account would not generate taxable gain under the “investment company” rules. The IRS also ruled on the effect of the interest disallowance provisions of § 264(f) on both banks. In the case of the bank with an interest of less than 50 percent in the LLC, the IRS ruled that there would be no interest disallowance under § 264(f)(1) on account of the LLC’s holding policies – on current or former employees – with unborrowed policy cash values.

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