Wal-Mart Stores, Inc. v. AIG Life Insurance

OPINION AND ORDER

LAMB, Vice Chancellor.

I

In the early 1990s, a large national retailer embarked on a plan to acquire corporate-owned life insurance (“COLI”) policies covering an enormous number of its employees. The principal purpose of this plan was to generate substantial federal income tax benefits for the retailer. Working with a number of insurance brokers and insurers, the retailer began purchasing blocks of policies in 1993 and continued these purchases until 1995. By then, the retailer owned life insurance policies covering hundreds of thousands of its employees.

In 1996, Congress…