Exhibit 1: Sample SERP Swap
Participant forfeits specified excess benefits.
Company pays premiums into a survivorship life
insurance contract owned by an irrevocable trust.
Participant contributes, via gifts in trust, part of
the annual premium equal to the economic benefit of the
Participant pays gift tax
(and GST tax, if applicable) on the economic benefit
contributions. Tax may be avoided by using available
Company recovers its premium
outlay before or at death. Split-dollar agreement
Life insurance trust receives
death proceeds free of income and estate taxes.