If someone could answer this quickly! These are questions involving gift and estate tax.

(4) Insured owned 60% of the voting stock of Corporation, which owned a policy on Insureds life. The minority 40% shareholder was beneficiary of the policy, but Corporation held the incidents of ownership in the policy.

(a) To what extent are the proceeds of the policy included in Insureds gross estate at Insureds death?

Answer: Policy Owned by Controlled Corporation: 100% of proceeds included in Ds estate. If D has ownership of more than 50% of the corporation, then the corporations incidents of ownership will be attributed to D.

Exception: if the proceeds of the policy are paid to the corporation, then the corporations incidents of ownership are not attributed to D.

Reason: proceeds increase the FMV of the stock, which is already included in the estate.

(b) To what extent are the proceeds includable if Corporation is the beneficiary of the policy?

(5) Taxpayer had an insurance policy on Taxpayers life on which Taxpayer had paid premiums for 10 years. The proceeds of the policy are $200,000 and are to be paid to Sibling on Taxpayers death. In the tenth year, Taxpayer conveyed the policy to Sibling, but, unless stated to the contrary, Taxpayer continued to pay the premiums. Taxpayer did not, however, retain any incidents of ownership.

(a) What are the estate tax consequences if Taxpayer dies two years after conveyance?

(b) What are the estate tax consequences if Taxpayer dies two years after conveyance, but Sibling has paid the post-transfer premiums?

(c) What are the estate tax consequences if Taxpayer dies four years after conveyance?