Use of Life Insurance in Estate Planning under the Internal Revenue Code of 1954

Life insurance, for tax purposes, has been treated as a separate type of property and, generally, the rules applying to other types of property are not applicable to insurance problems. Life insurance is supposed to receive favored treatment on the theory that it promotes the general good to encourage people to provide for their future and for the care of their dependents. I. Gifts of Life Insurance Policies … A. The Reversionary Interest Problem … B. Gift Tax Problems … (1) Gifts in Contemplation of Death … (2) Gifts and the Annual Exclusion … (3) Gift Tax on Beneficiary Designation by Donee … C. The Marital Deduction and Life Insurance Planning II. Provision against Apportionment Conclusion