@2013_CPA
both payor and beneficiary are employee, it is nontaxable to employee;
business entity may never take deduction for life insurance on key employees with entity beneficiary; but an IRC Sec telling that life insurance policy received upon key employee's death is tax free.
i guess u r mentioning book income <=> taxable income conversion.
life insurance paid for key employees with entity beneficiary is never deductible, hence it is added to book income to reach taxable income (or taken out from taxable income to reach book income-this process is also the process of converting taxable income to current E & P). notice, any increase in cash surrender value in policy must be reduced from the payment amount.
also, life insurance policy being distributed to entity upon keey employee's death is tax free, hence it is taken out from book income to reach taxable income. notice, any cash surrender value in distribution must be reduced from the distribution.
conversion may be tested much in partnership, corporation (schedule M-1, M-3 and CEP).