2. THE SIDE FUND SPLIT-DOLLAR SOLUTION™ © Copyright 2004All Rights Reserved.by The Weinberg Group, Inc. The Weinberg Group

3. Q. Why the Side Fund Split-Dollar Solution™? A. Tax Efficient Funding of: Estate Taxes Other Liquidity Needs Business Continuity Plans Buy-Sell Agreements Charitable Bequests Defective Grantor Trust Installment Notes

4. THE SIDE FUND SPLIT-DOLLAR SOLUTION™ Taxation as Economic Benefit (Endorsement) Split-Dollar Or Taxation as Split-Dollar Loan Two Exclusive Tax Regimes under Final Regs. after Sept. 17, 2003

5. THE SIDE FUND SPLIT-DOLLAR SOLUTION™ Measuring Annual Term Cost (“ATC”) Goal: Preserve Favorable ATC Taxation for as Long as Possible IRS Table 2001 Life Insurance Premium Factors Carrier Alternative Term Rates – Open Window of Opportunity?

6. THE SIDE FUND SPLIT-DOLLAR SOLUTION™ The Side Fund Split-Dollar Solution™ Implement Nonequity Collateral Assignment Split-Dollar Plan between Trust and Grantor (Private) or Employer (Corporate) Repay Grantor from Trust Side Fund or Switch to a Loan in Year in Which No Policy Equity Exists (“Rollout”) Repay Loans (If Any) from Side Fund During Life or Insurance Proceeds at Death Create Funded Defective Grantor Trust Using Gift Tax Lifetime Exemptions and Annual Exclusions Pay ATC or Interest from Side Fund Pay Continuing Premiums from Side Fund or Additional Loans

7. THE SIDE FUND SPLIT-DOLLAR SOLUTION™ Other Options Nonequity Split-Dollar for Life Split-Dollar Loans from the Outset Premium Gifts/Bonuses Financed Life Insurance Death Benefit Only (DBO) Plans Unfunded Collateral Endorsement Switch-Dollar™

9. Lifetime Exemption Gifts Annual Exclusion Gifts Grantor Trust (Side Fund) Insurance Company Mort and Mollie Berg Premiums Cash Value and Death Benefit = Greater of CV or Prems. Remaining Death Benefit ATC Contributions DURING SPLIT-DOLLAR PERIOD Taxable Income? (Grantor Trust)

10. Grantor Trust (Side Fund) Insurance Company Mort and Mollie Berg Continuing Premiums Repayment AT ROLLOUT Or Loan(s)

11. Grantor Trust (Side Fund) Insurance Company Mort and Mollie Berg Premiums Cash Value and Death Benefit = Premiums Remaining Cash Value and Death Benefit Interest and Principal Payments DURING LOAN PERIOD (IF ANY) Taxable Income? (Grantor Trust) Interest Deduction? (Personal Interest)

12. Income Tax Gift Tax I.R.S. Grantor Trust (Side Fund) GST Tax Ins. Death Benefit and Side Fund Estate Tax Surviving Spouse’s Estate Estate Assets Other Liquidity Needs AT SURVIVOR’S DEATH Mort and Mollie Berg

14. INSURANCE $10M Guaranteed No Lapse U.L. (Survivorship) Nonequity Collateral Assignment Split-Dollar Plan Grantor (Insurance) Trust Is Applicant, Owner and Beneficiary Insureds: Mort and Mollie Berg (Ages 65, 60, NS)

15. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

16. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

17. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

18. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

19. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

20. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

21. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

22. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

23. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

24. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

25. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

26. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

27. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - REPAYMENT

28. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

29. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

30. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

31. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

32. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

33. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

34. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

35. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

36. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

37. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

38. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

39. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

40. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

41. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

42. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

43. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

44. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY -

45. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - LE/AE GIFT PREMIUM GIFT

46. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - Projected Jt. L.E.

47. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - Projected Jt. L.E. TOTAL ROR

48. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - Projected Jt. L.E.

49. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - Projected Jt. L.E.

50. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - Projected Jt. L.E.

51. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - Projected Jt. L.E.

52. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - TRUST A/T ROR Projected Jt. L.E.

53. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - Projected Jt. L.E.

54. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - TRUST B/T ROR Projected Jt. L.E.

55. PRIVATE SIDE FUND SPLIT-DOLLAR SOLUTION™ MODEL USING SURVIVORSHIP LIFE INSURANCE Insureds: Mort & Mollie Berg, XYZ Insurance Company Policy #0123456 - THIS IS A SAMPLE CASE TO BE USED FOR EDUCATIONAL PURPOSES ONLY - 21.18% 64.18% 10.40% 31.50% 5.83% 17.67%

56. THE END