Split-dollar term loan Sample Clauses

Split-dollar term loan. The deferral charge for a split-dollar term loan sub- ject to paragraph (h)(2) of this section is determined by multiplying the hypo- thetical underpayment by the applica- ble underpayment rate, compounded daily, for the period from the date the split-dollar loan was made to the date the interest is waived, cancelled, or forgiven. The hypothetical under- payment is equal to the amount deter- mined under paragraph (h)(2) of this section, multiplied by the highest rate of income tax applicable to the bor- rower (for example, the highest rate in effect under section 1 for individuals) for the taxable year in which the split- dollar term loan was made. The appli- cable underpayment rate is the average of the quarterly underpayment rates in effect under section 6621(a)(2) for the period from the date the split-dollar loan was made to the date the interest is waived, cancelled, or forgiven.
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