The situation
Ray and Denise
Ray and Denise each own half of a commercial HVAC company in the Inland Empire. In 2012, when the business was worth about $1 million, their attorney drafted a buy-sell agreement. It said the company would buy back a deceased owner's shares for a fixed price of $500,000, funded by a $500,000 life insurance policy the company owned on each of them.
Fourteen years later, the company has grown to roughly $4 million in value. Nobody has touched the agreement.
This business and these people are hypothetical. Figures are rounded and simplified for illustration.
A new wrinkle
What Connelly v. United States changed
In June 2024, the Supreme Court decided a case involving two brothers with an agreement much like Ray and Denise's: the company owned life insurance and had to use it to redeem a deceased brother's shares.1
The Court held that the insurance proceeds counted toward the company's value for federal estate tax, and the company's obligation to buy back the shares did not offset that value.1 The result was a higher estate tax value for the deceased owner's shares.
For most owners this matters only if their estate could be large enough for estate tax. (Check yours with the Estate Tax Exposure Check.) But it's a reason to look at who owns the policies and how the agreement is structured, for example a cross-purchase between owners or other arrangements your attorney may suggest.