The Side Fund Split-Dollar Solution™:
A New Technique for Split-Dollar - Parts 1 and 2

by Lawrence Brody, JD, DAEP and Michael D. Weinberg, JD, AEP

Synopsis: The Side Fund Split-Dollar Solution™ is an innovative technique that—despite the split-dollar Regulations—allows clients and their families to acquire life insurance on a tax-favored basis that minimizes both income and transfer taxes.

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Lawrence Brody is a partner of Bryan Cave LLP, an international law firm, resident in the St. Louis office. He is the leader of the firm's Private Client Service Group and is a member of its Entrepreneurial, Technology & Commercial Practice Client Service Group. Mr. Brody is also a Fellow of the American College of Trust and Estate Counsel.

Michael D. Weinberg, JD, AEP, is the President of The Weinberg Group, Inc., a life insurance design and consulting firm in Denver ( He is a former co-chair of the Insurance Committee of the Real Property, Probate and Trust Law Section of the ABA and is the editor emeritus of The Insurance Counselor primer series published by that ABA Section. His e-mail address is


We do not express any opinion on the investment, legal, or tax consequences of this plan, and you are responsible for consulting your own investment advisors, legal counsel, and accountants for all such advice.

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