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Executive Bonus Plan (Section 162): How It Works and When It Beats Deferred Comp

A practical guide to Section 162 executive bonus plans, taxation, vesting decisions, restrictive endorsements, and high-impact design mistakes.

What a Section 162 Plan Is

  • The company pays bonuses that help executives fund personally owned life insurance.
  • Bonuses are usually deductible to the business and taxable compensation to the executive.
  • Because the executive owns the policy, portability is stronger than many nonqualified plans.

Why Owners Use Executive Bonus

  • Simple administration compared to complex deferred compensation agreements.
  • Retention leverage through bonus schedules and optional restrictive endorsements.
  • Potential long-term supplemental retirement liquidity through policy values if designed correctly.

Design Rules That Matter

  • Clarify whether bonuses are single, graded, or ongoing and tie them to performance logic.
  • Define who owns policy rights, beneficiaries, and collateral assignment terms from day one.
  • Avoid generic illustrations; model conservative assumptions and behavior risk.

Where Plans Go Sideways

  • Calling it a retention plan but giving full unrestricted control too early.
  • Ignoring executive tax impact and failing to coordinate gross-up decisions.
  • No documented annual review process for policy health and employment changes.

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