Supreme Court Upholds IRS Stance on Corporate Life Insurance Taxation
Unanimous ruling clarifies tax implications for closely held corporations using life insurance for share redemption.
- The Supreme Court ruled that life insurance proceeds used to redeem shares must be included in the corporation's value for estate tax purposes.
- The case involved the Connelly brothers' company, where life insurance funded the redemption of a deceased brother's shares.
- The court's decision resolved a conflict among lower courts on this tax issue.
- Justice Thomas emphasized that fair-market-value redemption does not reduce the value of the shares.
- The ruling suggests alternative succession planning strategies for closely held corporations.