A no-equity agreement is if an employee`s only benefit is a portion of life insurance against risks. In the case of a dollar stock split plan, the employee receives life insurance against risks and is also interested in the current value of the policy. Plans may allow the employee to borrow or withdraw some of the current value. (iii) After the transfer of the contract to E, E is the owner of the contract and all R premium payments are included in E`s income (unless R`s payments are split-dollar loans within the meaning of Article 1.7872-15(b)(1)). Finally, referring to Elkins7, the estate argued that Article 2703(a)(2) applied only to agreements for which the interest in ownership (in this case termination rights) exists or is created separately from the restriction (in this case MB Trust`s ability to prevent termination). The court found that Elkins did not say, and nothing in the statute indicates that Sec. The use of 2703 (a) (2) has thus been limited. Unlike many other ancillary benefit plans, split-dollar life insurance agreements were not built on the basis of legal or judicial laws. Instead, the tax consequences of split-dollar life insurance plans were largely controlled by a Revenue Ruling published in 1964 by the IRS.1 Although a Revenue Ruling is quite weak from a legal point of view, "split-dollar" insurance has become such a popular concept that virtually every employer has introduced some form of "split-dollar" insurance for one or more of its employees. (ii) To the Owner. .