MPI Case Alert: Cahill & Morrissette

Developments in the Cahill and Morrissette cases in June 2018 are expected to have significant ramifications on the structuring of split-dollar life insurance arrangements and may also have broader implications on intergenerational wealth planning and family entity structuring.  The broader impact is borne out of the tax court’s use of Internal Revenue Code Sections 2036(a)(1) and 2038(a)(2) to pull previously gifted assets back into the decedent’s gross estate for estate tax purposes.