The document describes a split dollar life insurance agreement between parents and their child. The parents take out a $15 million life insurance policy on the child and pay the premiums. The child loans the parents $6.12 million, which is used to pay the premiums. If the parents die first, their estate receives benefits including using the child's gift tax exemption and a discounted split dollar loan value. If the child dies first, the life insurance proceeds pay off the split dollar loan.