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Revenue Ruling 76-490

1976-2 C.B. 300 (1976)

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Revenue Ruling 76-490

Internal Revenue Service
1976-2 C.B. 300 (1976)

Facts

X Company entered an agreement with an insurance company to provide life insurance for X Company’s employees. X Company employee D took out a life-insurance policy through X Company and assigned all right, title, and interest in the policy to an irrevocable trust. The terms of the trust provided that the beneficiary or the beneficiary’s estate would receive the proceeds upon D’s death. Neither D nor the trust had any contractual right to continued payment of premiums by X Company. D did not report the premium payments as gifts. The Internal Revenue Service considered the issue of whether the premium payments might constitute indirect transfers subject to the federal gift tax.

Rule of Law

Issue

Holding and Reasoning ()

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