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Private placement life insurance is a form of cash value universal life insurance that is offered privately, rather than through a public offering. [1] It is typically only available to wealthy clients. A 2024 US Senate report alleged that the insurance mechanism in practice functions as a tool for tax avoidance, specifically for inheritance taxes, and was at the time being used to shelter up to $40 billion. [2] [3]
Variable or indexed life insurance is a form of life insurance that has cash value linked to the performance of one or more investment accounts within the policy. Because of its investment features, insurance carriers in the United States typically register offerings of variable life insurance with federal and state securities regulators. To register the offering, carriers typically need to provide some level of detail of the investment selections within the policy. Without knowing the specifics of each potential client's investment profile, carriers often settle for registering a uniform offering that includes a selection of mutual funds or hedge funds as investment options within the policy. Not all investments are suitable for placement within these policies. They are better suited to absolute return and hedged strategies rather than equity based investments. Because of the volatility of the stock market the drawdowns within the investment portfolio tend to be larger and the owner may end up having to put more money into the policy to keep it in force if the account value drops considerably.
This can become a very powerful tool for purposes of estate planning. In essence you can buy a hedge fund inside an insurance policy and the value will grow tax-free and upon death the cash value of the policy passes to heirs tax-free. See also Private Placement Variable Annuities.
By comparison, private placement life insurance is offered without a formal securities registration. The advantage with this approach is that the carrier customizes the investment options within the policy to meet the needs of the prospective investor. The key advantages to a private placement policy are there are no K-1s, vast investment platform and cost. Due to its nature, private placement life insurance is only offered to qualified purchasers seeking to invest large sums of money (often more than US$1 million) in the policy. In addition, an attorney will be needed to help draw up the documents, adding to the cost of the purchase.
While private placement life insurance ("PPLI") (a product also known as insurance wrappers) first developed offshore. United States carriers followed. The industry has witnessed significant growth in the placement of PPLI offshore. Offshore insurance companies specializing in PPLI typically offer the product as a financial service for high net worth clients and price their services as a provider, rather than as a traditional insurance carrier. For example, most offshore carriers are prohibited to maintain a domestic sales force. Also, offshore carriers cannot engage in onshore marketing.
The regulatory climate governing life insurance in certain offshore jurisdictions is also not as restrictive as may be found in the United States. Some of the better known jurisdictions to offer the product are Luxembourg, Ireland, Liechtenstein, Singapore, Barbados and Bermuda. While the lack of plentiful offshore regulation may not be comforting to traditional insurance consumers, high-net-worth individuals and their advisors are more likely to be able to carefully examine the merits and risks associated with insurance products from offshore carriers. Especially in Europe PPLI offers a lot of tax benefits. In all the European countries where the product is available the product offers at least a tax deferral, and in most European countries there are also substantial income, wealth and inheritance tax benefits. It is therefore that a growing number of financial advisors change existing offshore company, family foundation and trust structures in to PPLI solutions. The product also offers solid asset and investment protection features, which makes the product even more interesting.
Private Placement Life Insurance in one form or another is gaining popularity throughout Europe and the rest of the world as it is used in many cases as a substitute for a trust or Foundation or to strengthen existing structures by adding ‘substance’. Many Tax authorities are looking through trusts and not accepting the trustees as the legal owner of the assets and this can cause difficulties that are not experienced when using PPLI.
Due to the unique nature of the relationship between the life company, the individual and the contents of the life policy, PPLI can be used to overcome specific issues such as management and control, beneficial ownership and substance. Since the Life company is recognized as the legal owner of the assets, in most cases they will also be outside the reach of future creditors.
Protection and Privacy are a major feature of PPLI and a policy issued by a Luxembourg insurer is covered by the unique ‘Triangle of Security’. [4] With the introduction of directives in support of tax transparency by various governmental bodies over the last few years, the privacy of previously secure structures is not nearly so secure. [5]
A properly set up contract can also protect against bank failure and ‘Bail Ins’ by holding cash off any bank balance sheet, whilst at the same time often providing capital guarantees not available elsewhere.
In the current climate legislating on money laundering, tax evasion and avoidance, structures with real commercial substance will be expected and demanded and PPLI contracts can provide this on a compliant basis.
PPLI policies can be an invaluable resource for those seeking tax efficiency, a decreased reporting burden, asset protection or confidentiality. However, due to the complexities an experienced adviser with specialist knowledge of international insurance arrangements should always be consulted.
There exist a number of structures that provide clients security from data breaches, erroneous government reporting, and the "blanket and indiscriminate nature of automatic exchange under CRS". [6] Among these structures, Expanded Worldwide Planning (EWP) is a concept that has emerged. It offers international families a framework that enhances privacy and asset protection within a flexible, open architecture platform. For example, Advanced Financial Solutions Inc. is one proponent of EWP. [7] [8] It is an element of international taxation created to implement directives from several tax authorities following the 2008 worldwide recession. EWP gives privacy and compliance with tax laws. It also enhances protection from data breach and strengthens family security. [9] [10] It allows for a tax compliant system that still respects basic rights of privacy. EWP addresses the concerns of law firms and international planners about some aspects of CRS related to their clients' privacy. [11] [12] [13] EWP assists with the privacy and welfare of families by protecting their financial records and keeping them in compliance with tax regulations.
Insurance is a means of protection from financial loss in which, in exchange for a fee, a party agrees to compensate another party in the event of a certain loss, damage, or injury. It is a form of risk management, primarily used to protect against the risk of a contingent or uncertain loss.
The Gramm–Leach–Bliley Act (GLBA), also known as the Financial Services Modernization Act of 1999, is an act of the 106th United States Congress (1999–2001). It repealed part of the Glass–Steagall Act of 1933, removing barriers in the market among banking companies, securities companies, and insurance companies that prohibited any one institution from acting as any combination of an investment bank, a commercial bank, and an insurance company. With the passage of the Gramm–Leach–Bliley Act, commercial banks, investment banks, securities firms, and insurance companies were allowed to consolidate. Furthermore, it failed to give to the SEC or any other financial regulatory agency the authority to regulate large investment bank holding companies. The legislation was signed into law by President Bill Clinton.
A life insurance tax shelter uses investments in insurance to protect income or assets from tax liabilities. Life insurance proceeds are not taxable in many jurisdictions. Since most other forms of income are taxable, consumers are often advised to purchase life insurance policies to either offset future tax liabilities, or to shelter the growth of their investments from taxation. This insurance product is also known as Private placement life insurance.
Personal finance is the financial management that an individual or a family unit performs to budget, save, and spend monetary resources over time, taking into account various financial risks and future life events.
An offshore bank is a bank that is operated and regulated under international banking license, which usually prohibits the bank from establishing any business activities in the jurisdiction of establishment. Due to less regulation and transparency, accounts with offshore banks were often used to hide undeclared income. Since the 1980s, jurisdictions that provide financial services to nonresidents on a big scale can be referred to as offshore financial centres. OFCs often also levy little or no corporation tax and/or personal income and high direct taxes such as duty, making the cost of living high.
Variable universal life insurance is a type of life insurance that builds a cash value. In a VUL, the cash value can be invested in a wide variety of separate accounts, similar to mutual funds, and the choice of which of the available separate accounts to use is entirely up to the contract owner. The 'variable' component in the name refers to this ability to invest in separate accounts whose values vary—they vary because they are invested in stock and/or bond markets. The 'universal' component in the name refers to the flexibility the owner has in making premium payments. The premiums can vary from nothing in a given month up to maximums defined by the Internal Revenue Code for life insurance. This flexibility is in contrast to whole life insurance that has fixed premium payments that typically cannot be missed without lapsing the policy.
Universal life insurance is a type of cash value life insurance, sold primarily in the United States. Under the terms of the policy, the excess of premium payments above the current cost of insurance is credited to the cash value of the policy, which is credited each month with interest. The policy is debited each month by a cost of insurance (COI) charge as well as any other policy charges and fees drawn from the cash value, even if no premium payment is made that month. Interest credited to the account is determined by the insurer but has a contractual minimum rate. When an earnings rate is pegged to a financial index such as a stock, bond or other interest rate index, the policy is an "Indexed universal life" contract. Such policies offer the advantage of guaranteed level premiums throughout the insured's lifetime at a substantially lower premium cost than an equivalent whole life policy at first. The cost of insurance always increases, as is found on the cost index table. That not only allows for easy comparison of costs between carriers but also works well in irrevocable life insurance trusts (ILITs) since cash is of no consequence.
A structured product, also known as a market-linked investment, is a pre-packaged structured finance investment strategy based on a single security, a basket of securities, options, indices, commodities, debt issuance or foreign currencies, and to a lesser extent, derivatives. Structured products are not homogeneous — there are numerous varieties of derivatives and underlying assets — but they can be classified under the aside categories. Typically, a desk will employ a specialized "structurer" to design and manage its structured-product offering.
Ameriprise Financial, Inc. is a diversified financial services company and bank holding company incorporated in Delaware and headquartered in Minneapolis, Minnesota. It provides financial planning products and services, including wealth management, asset management, insurance, annuities, and estate planning.
A financial planner or personal financial planner is a qualified financial advisor. Practicing in full service personal finance, they advise clients on investments, insurance, tax, retirement and estate planning.
Bancassurance is a relationship between a bank and an insurance company that is aimed at offering insurance products or insurance benefits to the bank's customers. In this partnership, bank staff and tellers become the point of sale and point of contact for the customer. Bank staff are advised and supported by the insurance company through wholesale product information, marketing campaigns and sales training. The bank and the insurance company share the commission. Insurance policies are processed and administered by the insurance company.
Private banking is a general description for banking, investment and other financial services provided by banks and financial institutions primarily serving high-net-worth individuals (HNWIs) – those with very high income and/or substantial assets. Private banking is presented by those who provide such services as an exclusive subset of wealth management services, provided to particularly affluent clients. The term "private" refers to customer service rendered on a more personal basis than in mass-market retail banking, usually provided via dedicated bank advisers. It has typically consisted of banking services, discretionary asset management, brokerage, limited tax advisory services and some basic concierge services, typically offered through a gateway provided by a single designated relationship manager.
In the United States, an annuity is a financial product which offers tax-deferred growth and which usually offers benefits such as an income for life. Typically these are offered as structured (insurance) products that each state approves and regulates in which case they are designed using a mortality table and mainly guaranteed by a life insurer. There are many different varieties of annuities sold by carriers. In a typical scenario, an investor will make a single cash premium to own an annuity. After the policy is issued the owner may elect to annuitize the contract for a chosen period of time. This process is called annuitization and can also provide a predictable, guaranteed stream of future income during retirement until the death of the annuitant. Alternatively, an investor can defer annuitizing their contract to get larger payments later, hedge long-term care cost increases, or maximize a lump sum death benefit for a named beneficiary.
Premium financing is the lending of funds to a person or company to cover the cost of an insurance premium. Premium finance loans are often provided by a third party finance entity known as a premium financing company; however insurance companies and insurance brokerages occasionally provide premium financing services through premium finance platforms. Premium financing is mainly devoted to financing life insurance which differs from property and casualty insurance.
The following outline is provided as an overview of and topical guide to finance:
Australia's insurance market can be divided into roughly three components: life insurance, general insurance and health insurance. These markets are fairly distinct, with most larger insurers focusing on only one type, although in recent times several of these companies have broadened their scope into more general financial services, and have faced competition from banks and subsidiaries of foreign financial conglomerates. With services such as disability insurance, income protection and even funeral insurance, these insurance giants are stepping in to fill the gap where people may have otherwise been in need of a personal or signature loan from their financial institution.
A multi-family office (MFO) is an independent organization that supports multiple families to manage their entire wealth. Multi-family offices typically provide a variety of services including tax and estate planning, risk management, objective financial counsel, trusteeship, lifestyle management, coordination of professionals, investment advice, and philanthropic foundation management. Some multi-family offices are also known to offer personal services such as managing household staff and making travel arrangements. Because the customized services offered by a multi-family office can be costly, clients of a multi-family office typically have a net worth in excess of $50 million.
An offshore financial centre (OFC) is defined as a "country or jurisdiction that provides financial services to nonresidents on a scale that is incommensurate with the size and the financing of its domestic economy."
Juvenile life insurance is permanent life insurance that insures the life of a child. It is a financial planning tool that provides a tax advantaged savings vehicle with potential for a lifetime of benefits. Juvenile life insurance, or child life insurance, is usually purchased to protect a family against the sudden and unexpected costs of a funeral and burial with much lower face values. Should the juvenile survive to their college years it can then take on the form of a financial planning tool.
International tax planning also known as international tax structures or expanded worldwide planning (EWP), is an element of international taxation created to implement directives from several tax authorities following the 2008 worldwide recession.