I am working on terminating some split dollar insurance plans.  My
question is the following:  After the repayment of the premiums to the
employer is there a taxable portion remaining in the contract?  Does
it matter whether the amount remaining is exchanged for a different
policy or surrendered?  I need references to any and all material as
well.

Here is some of the specifics of the plan:

Equity Split Dollar
Collaterally Assigned
Terminating before January 1, 2004 and Began prior to the Temporary
Regs.