Based on various prior IRS rulings, the income tax treatment of split-dollar arrangements had been fairly settled for nearly 40 years.  However, to address certain perceived abuses of split-dollar arrangements and to provide a uniform statutory framework for determining the income tax consequences of split-dollar arrangements, the IRS in 2002 and 2003 issued proposed Regulations and a Notice.  These new Regulations and the Notice affect the income tax treatment of new split-dollar arrangements and may change the income tax treatment of existing split-dollar arrangements.