I am working on a gift tax return for a client of mine who transferred several life insurance policies to an ILIT his attorney set up. Each year, he and his wife plan to make cash gifts to the ILIT to cover the policies. I understand I can split gifts for the cash contributions made each year (the attorney drafts Crummey letters). My question – For the contributions of the initial policies to the ILIT, I am NOT split gifting since the policies were in his name. Is that correct, or does the contribution of those policies qualify for split gifting?