Disability premiums: Pay after tax or through corporation

Should you purchase pre-tax disability insurance designed to save you hard earned dollars now versus after tax dollars paid for a policy that will save you a lot more later? Obviously, if you do not collect on the policy by not getting disabled you are better off purchasing the pre-tax policy! But, what if you do get disabled and qualify for benefits. Mr. Tiffany in a recent example in “MGMA Connexion” laid out the alternatives. 
He assumes a $10,000 a month in benefits policy on which the corporation has paid $250/month for 10 years before getting disabled. 
Option of paying premiums pre-tax by corporation Total premiums paid: 120 months x $250/month = $30,000 paid out pre-tax Corporate tax rate of 33% tax savings $10,000. Net payments = $20,000 Benefits received: $10,000/month taxed at the corporate rate of 33% (paid to the corporation since premiums were paid by the corporation) = $6700 Assume ten years of disability or 120 months = $804,000 
Option of paying premiums paid after tax by physician He assumes a $10,000 a month in benefits policy on which the physician has paid $250/month for 10 years before getting disabled. Total premiums paid: 120 months x $250/month = $30,000 paid out after-tax Assume ten years of disability or 120 months = $1,200,000 
How about if you decide to switch and pay with after tax dollars rather then pre-tax which you have been paying with? If you get disabled within 3 years of making the switch, the IRS will use a complicated formula with a ratio of pre and after tax premium payments to figure out how much of the benefits are taxable? But, IRS ruling 2004-55 in 2004 allows you to bypass this ‘3 year look-back rule.’ The corporation creates a bonus fund from which to pay the premiums (162 Executive Bonus Plan). The bonus is not taxable to the corporation but is taxable to the physician. 
Comments: For details regarding group plans versus individual policies read Chapter 8 in my book " The Smarter Physician Volume 3.