Navigating 101(j) – an ounce of prevention can avoid a ton of liability

-by Ron Bielefelt


I was very annoyed.  It was the first application that I took for a key-person life insurance policy after August 18, 2006.  The underwriter kicked the application back because the insured-employee did not sign the “Notice and Consent” form, acknowledging that the employer was both the owner and beneficiary of the policy. When I suggested to the underwriter that we get this signature at delivery, he informed me that the policy would not be issued until the signed “Notice and Consent” was received.  This was bull, I never had to get this form in the past.  So, what was the big deal?

It turns out that this is a very big deal.  The rules had changed, and a new subsection had been added to §101 of the Internal Revenue Code.  The general rule of that subsection is that employer-owned life insurance death proceeds are taxable to the beneficiary to the extent they exceed cost basis, unless the requirements of 101(j) are met.  So where did this subsection come from?  Previously, my knowledge of 101(j) was non-existent – I even thought it might be an off-ramp on the famous 101 freeway in Los Angeles.  Knowing that I couldn’t change the map, I needed to learn more and find a way to navigate my client through 101(j).

Pensive businessman with maze

Here is what I found out.  Congress adopted these rules to prevent the perceived abuses of what was sometimes referred to as “janitor life insurance,” issued  for windfall profits.  These plans proliferated in the 1980’s as a form of Corporate-Owned Life Insurance, or COLI.

In a typical broad-based leveraged COLI transaction, a corporate employer would purchase policies on masses of lower-level employees, sometimes without the employees’ knowledge or consent. When an insured employee died, the company received the death benefits, and the employee’s family typically received either a small portion of the proceeds or nothing. These policies could remain in place even after the employee quit or retired.

In 2006, this all changed.

The COLI Best Practices Provision within the Pension Protection Act of 2006 became law on August 17, 2006. This provision was designed to codify industry best practices regarding employer-owned life insurance and amend the Internal Revenue Code by introducing conditions that must be met in order to exclude from gross income the proceeds from business-owned life insurance. The Act amended Section 101 of the Internal Revenue Code by adding subsection (j), “Treatment of Certain Employer-Owned Life insurance Contracts.” Briefly, the new subsection treats all employer-owned life insurance death benefits as taxable income, to the extent the proceeds exceed the premiums paid.  It also provides for exceptions to this rule, most notably requiring that the insured-employee sign a “Notice and Consent” form acknowledging that the employer is the owner and beneficiary of the policy.

[Related: The New Law for Business Life Insurance: Understanding Section 101(j) and Repairing Noncompliance]

Because of that change, employers today who purchase key person insurance and other forms of employer-owned life insurance need to watch out for a potentially costly trap — if the proper forms aren’t completed before the policy is issued, the death benefit is taxable, when it would otherwise be tax-exempt.  “The result is draconian,” says Jonathan Forester, a tax lawyer with Greenberg & Traurig in McLean, VA.  “If you’re expecting a death benefit of $10,000,000 and the IRS says you owe taxes, giving up 50%, if you’re a widow counting on these proceeds, that’s devastating.”

In a recent conversation with a hedge fund manager who bought $100 million of corporate-owned life insurance on his partner, but hadn’t complied with the rules of §101(j), we mulled over the options available to remedy the problem:

  • Go back to the carrier to get the policy reissued – providing that the carrier is willing and able to do this.
  • Cancel the original policy and issue a new one hoping that the employee is still insurable.
  • Do nothing and hope for the best – a gamble you do not want to take.

As you can see, the options are limited, difficult and potentially downright dreadful.  Now, I am no longer annoyed and have accepted reality. IRC Section 101(j) is far more important than my original take, and compliance with its requirements before policy issue is imperative for both you and your client.

An ounce of prevention avoids a ton of liability.

An excellent resource on §101(j) is a “White Paper” from Principal Financial Group.  It is a comprehensive piece that covers most of the details of IRC Section 101(j) in a “Question and Answer” format.  For example:

  • If the general rule of Section 101(j) is that employer-owned life insurance death proceeds are taxable, then how do death proceeds payable to an employer, from employer-owned contracts, qualify as tax-free under the general rule of IRC Section 101(a)?
  • Are death benefits from employer –owned policies payable to an insured employee’s heirs eligible for tax-free treatment under 101(j)?
  • What information must be furnished to the IRS in order to meet the new information return requirements?

As you complete annual reviews for your business clients there may be opportunities where replacement of non-compliant policies could save your clients thousands if not millions in income-taxable death benefit.  It will be worth your time to know the rules.

Download the “White Paper” and become familiar with Section 101(j). There are opportunities waiting for you.


Hire a World Class Marketing Organization – for $1 a Day

-by Marc Schwartz

With September’s arrival around the corner, our industry once again celebrates Life Insurance Awareness Month (LIAM). Created and produced by LIFE Happens and promoted by carriers and industry organizations, LIAM is a purposeful effort to raise consumer awareness with respect to client vulnerabilities and the solutions we deliver. Go to LIFE Happens to use all of the tools and resources available to help promote LIAM.  Danica Patrick is back as LIAM spokesperson with all-new videos promoting financial fitness.

Life Happens

For one month each year our industry makes a concerted effort to shine a spotlight on our products and the services we provide.  But what about the other 11 months of the year? How do we maintain, and take advantage of, the momentum generated by LIAM? Just as important, where do we as advisors fit into the equation? If a consumer is motivated to take action and handle their protection needs, who will they call and why? Millions of Americans need help — but will they ask you for direction?confusion1

As much as the internet might help consumers research their protection needs and potential solutions, the majority still turn to life insurance professionals to help them navigate the maze of companies and products.  And there remains a very important role to be played by a trusted advisor: simplifying what is complex and helping consumers sleep at night. How are you and your firm positioned given this enormous opportunity?  Think about the ways you need to market to Generation X and Millennials who now represent 145 million wallets.  (Related:  Millennials overtake Baby Boomers as America’s largest generation – Pew Research Center)  Marketing is now a multi-faceted, comprehensive and ongoing process that is a critical addition to efforts that are event driven.  You need to be and remain visible and available to clients and prospects.

If you are interested in expanding your business by addressing the protection needs of a huge and affluent, yet untapped market, then you need to be constantly  connecting with prospects and building your brand.  LIAM is a one-month program to soften the beaches, so to speak, but your disciplined and ongoing consistent push will ensure success. But how to do this?


Did you know you could plug into a cutting edge and comprehensive marketing platform for a cost of next to nothing? To me, what the Life Happens organization has built is one of the most powerful yet under-used marketing engines available in any industry.



Specifically, the Life Happens Pro package gives you the tools to push your brand, educate consumers, and establish yourself as a trusted advisor. Keep in mind that this is all about helping consumers understand their protection needs and vulnerabilities, be it life, disability or long term care, and there is never a product or carrier push. Fully customizable resources include:


  • Flyers, brochures and infographics
  • Social media content
  • Real life video stories
  • Turn-key email marketing campaigns
  • Need calculators
  • Insurance planning tools

Although there is a base level of tools available at no cost, the Life Happen Pro Plus package at $39/month is really where you want to start – and it offers a 30-day free trial so you can kick the tires. If you are truly interested in the future of your business and helping an underserved market, then I highly recommend this package. You will easily expand your brand without your budget taking a beating.

You can contact Life Happens directly at or (844) 824-5433; and feel free to contact me directly at or (800) 410-9890.

Happy 100th Birthday – There Goes Your Life Insurance

-by Michael “Woody” Wodchis, FLMI, ACS

Burning birthday candles number 100

The July 20, 2017 Wall Street Journal article, “Happy 100th Birthday!  There Goes Your Life Insurance,” points out a major hidden flaw in older life insurance contracts: the risk of living too long. In the mid-20th century, the life insurance industry, along with government regulators and actuaries, did not expect or anticipate that more than a handful of policyholders would reach age 100.  But today, some insureds fortunate enough to approach these “golden” ages are surprised to learn that their policies will “endow”– that is, coverage will end and any cash values will be paid to the policy owner. The Journal describes how one of those age 99+ policy owners, faced with losing all or part of what he originally intended to purchase – income tax-free death benefit for life – is taking his case to court.

For over a decade, “the industry has used age 121 as the standard maturity date in new contracts,” the newspaper reported. “But an unknown number of older contracts with the 100-year-old limit remain in consumers’ hands.” Many carriers subsequently added an Extended Maturity Rider (EMR) to their in force block to protect their policyholders against outliving their coverage, or provided other assurances that policies would stay in force indefinitely at the request of the policy owner, subject to some limitations (on loans or withdrawals of cash, for example).  Joseph Belth’s recent blog (The Age 100 Problem – The Achilles Heel of Life Insurance – Lands in Court) outlines the problem, and explains both the ways in which many carriers responded to this dilemma, and how others  simply chose to ignore the problem and let the original contract language prevail.  This recent press reinforces an absolute truth, as obvious as it may be, about life insurance death benefits: the policy must be in force upon the death of the insured for an income-tax-free death benefit to be paid. If a policy is 471267101cancelled, or endows as mentioned previously, any gain over the investment in the policy – premiums paid – is taxable to the policy owner.




The underlying problem, and opportunity, we have in the life insurance industry is to be aware of, and offer solutions for, longevity risk.  As mortality continues to improve, more of our clients will live into their 80s, 90s and even beyond 100. Even though carriers offer continued protection beyond this point, these improved product features won’t help if the policy is not in force.  Obviously, this is very important when the product is purchased for death benefit protection rather than other needs, such as supplemental retirement income.

We ask our clients to trust in our advice as well as in the suitability of the products and carriers we recommend. Where protection is the primary objective, what can we do to meet and exceed client and beneficiary expectations?


Presenting the lowest premium product may help win a case but may not be best for the client in the long term. Whether an existing policy or a new sale, all products need to be appropriately funded so that they have a realistic chance to last to life expectancy (at a minimum) and well beyond. With hopes of AG 49 leveling the playing field, we have actually seen indexed universal life illustrations become increasingly complex as many carriers project guaranteed or non-guaranteed bonuses. Unfortunately, “illustration games” do little to help instill a sense of certainty and predictability down the road.


Beyond your own servicing systems to ensure that clients are regularly communicated with and understand how their policies are performing, work with carriers with effective and proactive processes in place that clearly track how policies are doing, be it behind, on, or ahead of schedule. Just as important, these communications have to provide easy to understand guidance relative to adjusting premium payments on an annual basis.


To avoid unexpected and unpleasant surprises down the road, take advantage of low cost guarantees available today. This is particularly appropriate for risk-averse clients who would pay “a little more” to lock in future certainty. Once the exclusive province of no lapse guarantee universal life and whole life products, there are now very competitive variable and indexed universal life products available today with extended guarantees, ranging from beyond life expectancy all the way to lifetime. By using these low cost guarantees, we take can take a lever out of the hands of the insurance company and help clients sleep at night.

Living Benefits

As clients live longer, their chance of living with extended and debilitating illnesses also increases in direct proportion. The various living benefit riders now available on life insurance products can provide much-needed funds to help offset the cost of care. In addition, there are riders that allow the policy owner to “convert” death benefit into a stream of retirement income…a powerful feature for clients who have lived longer than they might have expected.

Historically, the insurance industry has addressed longevity risk with its annuity products – products designed to provide an income that clients could not outlive.  Today, our professional recommendations must also consider a client’s potential longevity risk as it relates to life insurance products. As Joseph Belth explains:

“It is an understatement to say the age 100 problem is serious. Indeed, I think the problem is the Achilles heel of life insurance. The bedrock principles of life insurance marketing are the income-tax-deferred inside interest and the income-tax-exempt death benefit. The problem is so serious that . . . the companies do not want to discuss the matter. I further believe that neither the Internal Revenue Service (IRS) nor the income-tax-writing committees of Congress want to discuss the matter.”


Despite what the companies, the IRS or the Congressional committees might want, your clients need you to review their life insurance and examine the contracts for the kind of longevity risk that Belth and the Journal describe. If you find that you’re not sure how to start or what to look for, call us at Windsor.  We’ll be glad to help.




$522 Billion


A 2014 study by the RAND Corporation estimated the cost of informal caregiving in the US at $522 billion:  “Across America, people spend an estimated 30 billion hours every year providing care to elderly relatives and friends. The cost is measured by valuing the times caregivers have given up in order to be able to provide care.”  Those numbers continue to grow in 2017, as the baby boomer generation ages and creates greater demand for long-term care services.

Numbers like this get everyone’s attention, and long-term care (LTC) is a concern that is at once personal, cultural and political.  Those of us in the insurance business know there is a solution – one that’s been around for several decades:  Long-term Care insurance (LTCI).  But what’s happening to sales of LTCI amid these growing concerns and exponentially increasing numbers?

Six leading LTCI companies recorded increased policy sales in 2015 compared to their sales during the prior year according to the American Association for Long-Term Care Insurance. “This is a positive sign as is the fact that one new insurer began selling policies in 2016,” declares Jesse Slome, director of the American Association for Long-Term Care Insurance (AALTCI).  However, according to Slome, overall sales of traditional LTCI continued to decline compared to the prior year.  “The number of new policies (lives) sold in 2015 was down around 20 percent.”

The problem, according to Slome, is that, “Consumers we speak with perceive that LTCI protection is expensive, that insurers seek continual rate increases, and they express concern after reading online reports about denied claims.”  Though that perception may be mistaken in some ways (the industry paid over $8 billion in claims in 2015, a 4% increase over 2014), the reality is that sales of stand-alone LTC policies have been steadily declining for 15 years.  But ignoring the problem doesn’t make it go away.


“Here’s a stunner,” writes Richard Eisenberg for Forbes, “the average American underestimates the cost of in-home long term care by almost 50%,” according to findings in a 2016 Genworth Cost of Care study.  Still, in the midst of this growing disconnect between perception and reality there is a bright spot:  sales of combination and hybrid products with LTC benefits are on the upswing.

In May 2016 The National Association of Insurance Commissioners (NAIC) teamed with The Center for Insurance Policy and Research to create an exhaustive report:  The State of Long-Term Care Insurance: The Market, Challenges and Future Innovations.  In their section on LTCI products, they explain the appeal of hybrids in today’s marketplace:

“The hybrid product market has experienced substantial growth at the same time that standalone LTCI sales have collapsed and stagnated. . . . Hybrid products are appealing to customers, with particularly good alignment with consumer attitudes of the baby-boom generation, which now entirely comprises the target market for LTCI products. The products are fairly simple and can be easily explained to consumers. Generally, the customer has already made a decision to purchase life insurance or an annuity contract, and the step of making it a hybrid product is as simple as a choice to add a rider with LTC features. The customer is simply being advised of an optional feature which allows the ability to access his/her death benefit or account value in the event LTC is needed.”



Hybrids continue to evolve into new and better options for consumers, offering an array of innovative features and benefits, including

  • Residual Death Benefits
  • Inflation Protection
  • Return of premium features
  • Coverage for permanent and/or temporary conditions
  • International Benefits
  • Life policy lapse protection while on claim
  • Non-forfeiture options which preserve some benefits even if premiums are unpaid
  • Skilled nursing home care; adult day care; assisted care; home health care; intermediate care; hospice care
  • Family care (see “$522 billion,” above)
  • Guaranteed Issue contracts (call us for details on this)
  • Payment of benefits in full, through long-term care benefits and/or life insurance death proceeds

Additionally, insureds maintain control of the amount of the payment and enjoy a high degree of flexibility:

  • Insureds choose how much of the monthly benefit is received, up to the benefit maximum
  • As long as the insured is receiving care from a licensed care facility or service, excess benefit payments that are not needed to pay for care can be used for any other purpose
  • Insureds may choose to receive less of the LTC benefit than they are eligible for to preserve their policy benefits, effectively “stretching” the LTC coverage period



With all this flexibility comes a perplexing amount of information and choices.  Which means offering your client sound, informed advice about suitable products becomes vitally important.

At Windsor, we work with these products every day.  We understand the complexities and provisions of hybrid products including Hybrid Life/LTC (Lincoln’s MoneyGuard), life insurance with true 7702(b) Long Term Care (Nationwide, John Hancock, AXA), pre-underwritten/paid chronic illness riders (Prudential, American General), and embedded (free) discounted chronic/critical illness riders (American National, North American, Symetra).


We’ve found the money.  The market is worth $522 billion. We can help.



The State of Estate Planning – 2017

You probably feel as if the field of Estate Planning is in turmoil right now – uncertainty about income taxes, estate taxes and wealth transfer solutions seems so disruptive that Larry Brody, a widely respected estate planning practitioner, has titled an upcoming  presentation:  “What the Hell Do We Do Now?”confusion1

Is it really that bad?  Well, here are links to two excellent and recent AALU publications that may help answer that question.

The takeaways, first from the Survey: “Even in the face of major tax reform, clients and their advisors should remain optimistic and steadfast in their approach to implementing life insurance and legacy planning. Flexible, multi-faceted planning that can address both practical and tax issues is at a premium. Life insurance remains an ideal solution because of: (1) its unique attributes (instant, mortality-based liquidity and cash accumulation and death benefit payments on a tax sensitive basis) and (2) its ability to serve many critical objectives (tax, retirement, and liquidity planning, investment management and diversification, and family security).”

And from the Heckerling Institute: “Overall, Heckerling presenters were optimistic regarding the current planning environment, particularly as this is not the first time that the estate and life insurance industry has dealt with the prospect or passage of major tax changes (e.g., 2010 and 2012). Many planning approaches, like trusts, estate freezes, and life insurance, are inherently flexible and multi-faceted, and tax changes can actually enhance different structuring options and benefits. Accordingly, this environment should trigger thorough audits of client plans and open the door for a dialogue between allied professionals and clients, with interest in life insurance products continuing as both a solution to practical needs and as a complement to other planning approaches.”

We encourage you to read through both the Survey and the Heckerling Institute summary to help clear up some of the hyperbole and confusion that often arises when there’s talk of major tax policy changes.

Golden key and puzzle

If you’re like us, you’ll realize that 2017 will continue to offer plenty of new opportunities for planning and insurance professionals, no matter which way the wind blows.





The no good, ugly, scary future of life underwriting

-by DuWayne Kilbo

The tension is palpable.

Underwriting is being turned on its head, driven by big data, automation, alternative risk assessment tools, and more predictive underwriting models and processes augmented by analytics.

Go to any underwriting industry meeting and there will be considerable time and energy devoted to one or more of these topics, along with a fair amount of angst among the underwriting folks present.

Traditional and new industry players speak about the latest risk assessment models and tools, back-tested through hundreds of thousands of client records and data points, producing mortality results similar to existing methods at a fraction of the cost and in light speed when compared to most existing underwriting processes.  In addition, these new tools require less, and sometimes no, human underwriting intervention.


A new world of life underwriting is being ushered in. And it’s scary for the underwriting profession.

Driven by the under-served and uninsured markets, aging and shrinking producer distribution models, increases in carrier retention (with a focus on mortality as a profit center), a need to find new sources of revenue, direct to consumer distribution models, and technology players promoting lower cost and faster underwriting methods, the table has been set for change.

For the underwriting profession change was needed, and some would suggest long overdue.  Underwriting has been pretty much “business as usual” for the past 25 years. Today, long waits of up to several weeks typically occur for a policy to be approved and issued—even for simple, modest face amount cases.  No business or industry can expect to be successful or even survive long-term using this type of model.

On top of this, consumers, especially younger buyers, are demanding a better insurance acquisition experience, and don’t care about the disruption that creates for the life industry and its various players.  Though it may be an overstatement to say that traditional life underwriting is facing an existential threat, it could go down that road if the industry doesn’t adapt to customer needs and wants. The industry needs to keep things affordable, and make processes faster and easier for the insurance buying consumer.

So what does this mean for the life underwriting industry?  Is this no good, ugly, and scary for the underwriting profession?

In some respects, yes.

But in more important aspects where underwriting talents and skill sets are essential, no.

First, with new data sources and underwriting tools, predictive models, automation, and perhaps even artificial intelligence, the demand for underwriters—on a pure numbers basis—will be less.  This will be viewed as a negative by some, and certainly doesn’t feel good for the people impacted.

It’s absolutely necessary to automate and streamline as much as possible in ways that make sense and provide value to the customer.  No business survives or even thrives without addressing what customers need and how they want services or products delivered, with much of the delivery achieved through automation. This may require fewer underwriting resources, and it is inevitable.

However, while automation, predictive analytics, and other newer tools lend themselves to clean cases with reasonable face amounts, they don’t necessarily provide the same level of comfort for large face amount and medically impaired risks.

These latter cases require high level human intervention, where complex thought and interaction are required.  This is what underwriters provide to the risk appraisal process. Also, these things are difficult, if not impossible, to program into algorithms. While new tools and data sources may add to or support decision-making and perhaps streamline processes, mispriced mortality is unforgiving. Replacing the human element in these situations is risky and very unwise.

Second, besides technical skills, underwriters possess “soft” human interaction talents to create loyal customers and repeat business. Through their knowledge, understanding and engagement, underwriters have unique perspectives to interact with carriers, and among sales organizations, producers, customers and others.  These skills are extremely valuable and cannot be algorithmically programmed.  Just try to create any type of dialogue with “Siri” or “Alexa” and you’ll see what I mean.

Lastly, underwriters provide leadership to help guide their organizations and industry through challenges and to the next level, especially concerning mortality-related issues.  Some underwriters are very good at doing this within their organizations and industry, while others are not.  For those who are not it is imperative that they get better.  And some companies are very good at inclusive decision- making, while others are not. In either case, underwriting must find or create a place at the table to have an impact on the direction of their companies and the future of the life insurance industry.

The future for underwriting in this writer’s opinion is exciting—not “no good, ugly, or scary.”

With any change comes opportunity.

There is so much to be done and accomplished.  By learning new skills and uncovering new talents to propel the profession and industry forward, underwriters can provide additional value to their organizations and to others. This may include learning things beyond what they do today, such as statistical analysis, data applications, products, illustrations, sales concepts and more, providing fresh perspectives and new solutions for their organizations, customers and production sources.


For over 40 years, Windsor has responded to change in ways that created new advantages and opportunities for everyone we work with.  It’s what we do.

Now is the time for revitalization.

The future doesn’t need to be scary.







A split dollar power play made Jim Harbaugh college football’s highest paid coach — what was that about?

– by Marc Schwartz

Last summer ran the headline: Michigan, Jim Harbaugh agree to increased compensation in form of life insurance loan.  We suspect that most sports fans just shrugged and moved on to see how the Cubs were doing, but those of us in the life insurance business sat up and took notice.  After all, we seldom get any press on the business page, let alone the sports page.  And this was indeed big news about a big compensation boost, using a relatively little-known but powerful combination:  Split Dollar and cash value life insurance.

Lightning dollar sign

(Related:  American Institute of CPA’s:  Split Dollar Insurance Plans)

ESPN’s article, though, did not use the words “split dollar” at all, and that was fine.  Sometimes we get  caught up in our own jargon and forget that people outside our industry – clients, CPAs, sports writers, for instance – only care about what the arrangement accomplishes.  Not only did this new agreement make Harbaugh the highest-paid head coach in college football, it left some other notable coaches in the dust.  (USA Today:  NCAA Football Coaches’ Salaries)  In this blog we’ll explain why both Michigan and coach Harbaugh found this unusual approach to be in their mutual best interest, regardless of what the plan is called.

At its simplest the arrangement looks like this:  the university loans $2 million a year to the coach for seven years in the form of premiums paid for a life insurance policy on the coach’s life.  The coach will pay no interest to the university, and will instead be required to pay tax on that unpaid interest as imputed income from the university.  The rate used to calculate that imputed income is determined in the Internal Revenue Code and published monthly by the Treasury Department as the Applicable Federal Rate (AFR).  In return, policy values secure the loan – both the cash values and the life insurance death benefit can be used to repay the loan, should the university and coach part ways, though there are additional strategies to exit the arrangement that might prove less painful.  For the coach, you can see the advantage to this right away:  life insurance payable to his spouse and children, cash value growing inside the policy tax-deferred, with the potential  to use that cash value in the future (preferably after several national championships).  All in return for the tax bill on the imputed income from foregone interest, based on what are currently very low interest rates (the February 2017 AFR for this kind of loan is a little over 1%).

So what’s in it for the university?  First, the arrangement ties the coach to the school for several years in order for all of the numbers to work to the coach’s full advantage.  The life insurance benefit is there from day one, but there is much more of a reward, in the form of potential equity available for tax-free policy loans when the coach retires, along with substantial long-term life insurance death benefits for the coach’s family.  Take a look at the sample presentation we have put together for a similar plan using an Index UL product to get an idea of how attractive this can be over the coach’s lifetime, and how much of an incentive it can be to keep the coach close to home.  Second, the university’s loans are secured.  The values in the policy provide the university with some assurance that its investment may be recovered if things don’t work out as planned.

While it may be a surprise to find this kind of insurance-based solution headlining the sports page, such plans have broad application in executive compensation arrangements for all kinds of businesses.  In fact, the more attractive it becomes to spend money at the corporate/business level (because of lower corporate tax brackets), the more effective such plans can be.  So, the next time you are looking for a life insurance solution that can strengthen the executive-employer relationship and provide an incentive for a valued employee to stay on until retirement, remember the University of Michigan, coach Harbaugh – and Windsor.