Additional comments on EWP
Structuring in Puerto Rico—the best of “the new Switzerland” Expanded Worldwide Planning (EWP)
In case you didn’t, please read the “Expanded Worldwide Planning (EWP)” blog post.
Top international tax planners have been quick to realize the implications of our last white
paper, “Structuring in Puerto Rico—the best of “the new Switzerland.” Indeed, one advisor
coined the phrase “Expanded Worldwide Planning” to describe the new paradigm. We have
espoused this phrase as the title of our short Addendum to our white paper and will be
clarifying some of these new possibilities for your planning toolkit. With EWP, the trust or
entity can be domiciled anywhere the client wishes it to be and so can the assets be located
anywhere in the world. Over the last few years, many of the international families we serve
have been described as Global Citizens. In parallel to that, EWP can be viewed as Global
If one accepts the tenets outlined in, “Structuring in Puerto Rico—the best of the new
Switzerland,” that is backed up with a very positively worded legal opinion letter by a major
international law firm, it becomes obvious that the Puerto Rican Private Placement Life
Insurance policy functions merely as a second trust to secure the advantages of Puerto Rico’s jurisdictional position. These advantages have been strengthened by the recent elections in the US, as well as the voices that have been raised about legal and data breach issues inherent in CRS.1
Ironically, under the umbrella of an EWP structure, planning possibilities are expanded rather than diminished as a result of FATCA and CRS. EWP allows for a tax compliant system that still respects basic rights of privacy. It assuages the quite significant objections many major law firms and international planners rightfully raise against certain aspects of the CRS.2
They are not seeking to hide client assets from tax authorities but do intend to protect their
clients’ privacy, which EWP allows them to do.
With the massive amounts of data being exchanged under CRS about to commence, the risk is high for the right of attorney client privilege to be pierced by groups of journalists working in consort in the name of tax transparency.
This has already become apparent in past experiences such as the Panama Papers. It will take years for all the implications of CRS to be worked out, if indeed it lasts that long.
Why not embrace a structure that bypasses the confusion and discord that will ensue in this process? Advanced Financial Solutions seeks to secure its clients in a tax-advantaged and privacy-advantaged environment. We are not looking to hide client assets and work only with those who have undergone a most thorough KYC and AML process. We invite you to explore EWP with us, and welcome your questions and inquiries.
Download the full PDF with endnotes: EWP addendum final (pdf)
by Michael Malloy CLU TEP RFC, @ Advanced Financial Solutions, Inc