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PPLI and EWP Financial

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Private Placement Life Insurance and EWP Financial

Why EWP Financial?

(Updated)

EWP Financial is one of a handful of firms worldwide that specialize in Private Placement Life Insurance (PPLI). Even so, EWP Financial sets itself apart from this elite niche because it markets itself directly to the world’s wealthiest families, while its competitors rely mostly on referrals from other professionals.

How does EWP Financial accomplish the daunting task of reaching the world’s wealthiest families directly? In part by the fact that its founder and director, Michael Malloy, has authored two books on PPLI, written hundreds of articles, and produced close to 50 videos on its YouTube channel, EWP Financial, all with the specific purpose of reaching out directly to wealthy families.

Latest Article: PPLI – A way to preserve wealth

What ever induced EWP Financial to set out on this most difficult course? Here is what Mr. Malloy says:

“Over the years, I have found that wealth creators are able to grasp the unique benefits of structuring their assets using PPLI quite readily. Once they understand the considerable benefits and show willingness to come on board, we can then also educate their tax and legal advisors. This process has proven itself to be more effective and expedient.”

“The wealth creators have an intuitive sense honed by many years of business experience. They understand complex issues without having to delve immediately into technical issues. We can then provide their advisors with the appropriate tax codes and examples of the many structures that we have successfully completed if they so wish. Most often, the advisors then readily come on board as well.”

Why do advisors need to be educated on this subject? Alas, there are no questions on the CPA or the bar exam about PPLI asset structures. Thus professionals need to learn about these specialized structures in the midst of their practices. They would also have to have a practice that includes the world’s wealthiest families. This then is a rarefied group and most advisors welcome the expert education we provide.

EWP Financial enjoys the challenge of reaching the select audience of the world’s highest wealth achievers. We at EWP Financial, have carved for ourselves a niche with few competitors, and are very happy to have done so.

Michael Malloy, CLU TEP RFC.
CEO, Founder @EWP Financial

~ Your best source for PPLI and EWP

The Expanded Worldwide Planning Stories Video Series – Part 1 – Episode 4

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International Tax Planning

#EWP : Insures: PRIVACY – Video 4

Intro
In this video we conclude our story on Privacy. Carlos Gutierrez attempts to heal the emotional devastation brought about by the kidnapping of his daughter and a falsified lawsuit, both engineered by a ruthless, Mexican drug cartel.

Carlos is brought to the realization that he needs an asset structure that will shield his business and family from these catastrophic events. That asset structure is easily obtained by employing the six principles of Expanded Worldwide Planning, or EWP for short. This is what our firm, EWP Financial, provides to all families who use our services.

by Michael Malloy, CLU TEP RFC.
CEO, Founder @EWP Financial

Q & A – Ancient Wisdom and PPLI

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Questions and Answers from the book “The Wit and Wisdom of Professor PPLI: How to Achieve Exceptional Asset Structuring with Private Placement Life Insurance”

~ by Michael Malloy, CLU, TEP

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Socrates and King Lear Teach Us a Lesson

Ancient Wisdom and PPLI

Section 3, Part 4

In this Part of the book, Socrates and Shakespeare’s King Lear are mentioned. Professor PPLI, please tell us more about how they pertain to PPLI?

In this Part of the book, we used the death of Socrates and the wanderings of King Lear late in his life as examples of highly charged types of exile. Socrates was put to death by state officials in Athens. King Lear was left to wander in his own country after political intrigue forced him out.

Wealthy families are not immune to dramatic forms of exile, sometimes being forced to flee their own country for political and economic reasons. At Advanced Financial Solutions, Inc., our goal is to structure your assets into a well-organized arrangement that gives you the stability to withstand disruptive cross border changes.

This is accomplished through the conservative vehicle of life insurance that is recognized in almost all jurisdictions throughout the world as a standard financial planning vehicle. Privacy, asset protection, and tax efficiency are the hallmarks of the structures that we provide for wealthy families throughout the world.

Profession PPLI, how does Socrates’s philosophy teach you to construct better PPLI international asset structures?

Achieving the ideal international asset structure requires us to be careful listeners. We zealously guard against presenting you with a preconceived plan of our own making. In the end, the plan must be a combination of your aims and desires and our knowledge of the laws and regulations that are pertinent to the plan. What worked for one family may not be a fit for you, even though the outward facts are similar.

How can we be certain that we adhere to careful listening? One method is to follow Socrates’s famous quote: “I only know that I know nothing.” Garth Kemerling’s insightful commentary in the Great Philosophers series is helpful here:

“It is one thing to state one’s opinion of how things are and should be. Powerful institutions such as religions and political systems are built upon such dogmas and the demands that others abide by them. Socrates, on the other hand, started from a position of ignorance and sought the truth. In the end. He has no dogmatic program for us to follow, just a method for seeking the truth for ourselves, without any guarantee that we will find it. Philosophy as practiced by Socrates is an open system.”

Professor PPLI, why would a citizen of a country wish to purchase a life insurance policy from a company outside the borders of their country?

The majority of jurisdictions in the world allow their citizens to purchase life insurance from companies outside their borders. PPLI serves this need very well.

For reasons to purchase a foreign life insurance policy, you need look no further than the six principles of Expanded Worldwide Planning (EWP):

Privacy
Asset protection
Succession Planning
Tax Shield
Compliance simplifier
Trust substitute

Usually several, if not the majority of these six principles, are not available in your own country. Why restrict your international asset planning to just the meager offerings that are available. Expand your vision to include the full palette of EWP. We quote the definitions of the six principles from the Wikipedia page, “International Tax Planning:”

Privacy

EWP gives privacy and compliance with tax laws. It also enhances protection from data breach and strengthens family security. EWP 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. EWP assists with the privacy and welfare of families by protecting their financial records and keeping them in compliance with tax regulations.

Asset protection

EWP protects assets with segregated account legislation by using the benefits of life insurance. This structure uses asset protection laws in the jurisdictions of residence to shield these assets from creditors’ claims. A trust with its own asset protection provisions can still receive additional protection with the policy.

Succession planning

EWP includes transfers of assets without forced heirship rules directly to beneficiaries using a controlled and orderly plan. This element of EWP provides a wealth holder a method to enact an estate plan according to his/her wishes without complying forced heirship rules in the home country. This plan must be coordinated with all the aspects of a properly structured PPLI policy together with other elements of a wealth owner’s financial and legal planning.

Tax shield

EWP adds tax deferral, income, estate tax benefits and dynasty tax planning opportunities. Assets held in a life insurance contract are considered tax-deferred in most jurisdictions throughout the world. Likewise, PPLI policies that are properly constructed shield the assets from all taxes. In most cases, upon the death of the insured, benefits are paid as a tax free death benefit.

Compliance simplifier

EWP adds ease of reporting to tax authorities and administration of assets, commercial substance to structures. In addition, the insurance company is considered the beneficial owner of the assets. This approach greatly simplifies reporting obligations to tax authorizes because assets in the policy are held in segregated accounts and can be spread over multiple jurisdictions worldwide.

Trust substitute

EWP creates a viable structure under specific insurance regulations for civil law jurisdictions. It also creates a new role for commercial trust companies. In most civil law jurisdictions, trusts are poorly acknowledged and trust law is not well developed. As a result, companies with foreign trusts in these civil law jurisdictions, face obstacles.

Please let us know how we can put these six principles of EWP to work for you. Contact us for a no-charge initial consultation that will be tailored to your own individual aims and desires.

by Michael Malloy, CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #PPLI #privateplacement #lifeinsurance #advancedfinancialsolutions

Q & A – Nothing Is Impossible

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Questions and Answers from the book “The Wit and Wisdom of Professor PPLI: How to Achieve Exceptional Asset Structuring with Private Placement Life Insurance”

~ by Michael Malloy, CLU, TEP RFC

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Nothing Is Impossible

PPLI: Under Higher Laws

Section 3, Part 3

Professor PPLI, attitudes toward a subject are a powerful force in how people perceive the subject. These attitudes are also sometimes hard to change. How does this relate to PPLI?

If you study the history of science, you can readily see how once a long held belief or attitude is changed, it becomes a new paradigm that awaits another future paradigm shift. What was thought impossible becomes possible.

A similar phenomenon exists in sports with world records. Take Roger Bannister breaking the four minute mile record. In a sense, once the barrier is broken, others are given permission to accomplish the same feat. Again, the impossible becomes possible.

In the world of PPLI, I see a paradigm shift coming for professional trustees’ attitudes towards PPLI asset structuring. Professional trustees can be distrustful at first hearing of these structures, because they think they will lose control of the assets. Exactly the opposite is the case.

When assets are placed in a PPLI structure, the insurance company takes over the administration of these assets, but leaves the trustee in ultimate control. This relieves the trustee of many routine tasks, but the trustee retains their role as the ultimate decision maker, since they are the owner of the policy. They are even free to switch insurance companies, if the administration of the assets is not to their liking.

In a Wealthmanagement.com article, “Private Placement Life Insurance Primer, Recent tax law changes make for a particularly interesting time to explore PPLI,” Brian Gartner and Matthew Phillips explain why some trustees are particularly attracted to PPLI.

“Trustees are attracted to PPLI in the context of multi-generational trust planning for three main reasons: (1) assets within a trust allocated through PPLI grow on an income tax-deferred basis; (2) the trustee can make income tax-free distributions to trust beneficiaries from PPLI without having to consider the income tax consequences of liquidating assets; and (3) the trust will eventually receive an income tax-free insurance benefit, which will serve to effectively step-up the basis of the assets within the trust that are allocated through PPLI.”

Lastly, assets within a PPLI structure are frequently held for the long term, usually until the death of the insured person, thus, the trustee can be assured of controlling the assets for a long time period.

The title of this section is “Nothing Is Impossible.” This is a big statement. What relevance does this have to PPLI?

To solve issues in the world of international asset structuring, it is sometimes necessary to ask the simple, yet sometimes profound, questions that come from children: why is the sky blue? And where was I before I was born?

At Advanced Financial Solutions, Inc., we ask ourselves one simple question at the beginning of each client engagement:

How can we achieve the maximum amount of tax efficiency, asset protection, and privacy for this family?

Our picture in the book is telling for the answer to this question. Nobody has told the mountain goats in this picture that what they are doing is extremely dangerous and they can fall to their peril at any point.

Our task at Advanced Financial Solutions, Inc. is not so dramatic, but we do endeavor to achieve what might seem impossible by conventional structuring methods. How do we accomplish this? By engaging you with simple questions that bring about the answer to the important question posited above.

Ironically, our international PPLI structuring techniques are usually far more conservative than the complex trust structures that clients frequently bring us to review. Sometimes they have spent weeks pondering over this overly complex structure and still do not understand them.

We treat each of our cases as a blank canvas that confronts each painter at the beginning of a painting project. Our goal is to paint, read structure, a picture that gives a family all they desire in the realm of tax efficiency, asset protection, and privacy.

Professor PPLI, how is PPLI similar to the popular phrase, “to hide something in plain sight?”

The key to this question lies in two words–life insurance. Most all life insurance policies in most jurisdictions throughout the world offer all or some of these benefits:

Tax-deferred growth of internal cash value
Tax-free death benefit
No capital gains taxes
No income taxes
Ability to access Cash Value through tax-free loans
Ability to manage or mitigate estate taxes

PPLI now adds these benefits:

Invest in almost any asset class
Increased asset protection as insurance company becomes beneficial owner of assets in the policy
Simplified reporting and privacy as only total cash value is reported
Policy can hold CFC’s and PFIC assets on a tax-deferred basis
Excellent vehicle to hold real estate
Provided a stable, globally recognized structure for tax authorities

Most attorneys, asset managers, trustees, and accountants have received no formal education in PPLI international asset structuring, and their professional societies have scant knowledge on the subject. After they drop their frequent preconceived prejudices against life insurance, and study the subject of variable life insurance, and the tax code that supports it, they usually have two reactions.

One, is they are astounded that they have not been using this simple and conservative method from the beginning of their practice. Or, two, they think it is too good to be true and reject it, because it does not conform to the methods that most of their peers use in the field of international asset structuring.

At Advanced Financial Solutions, Inc. we encourage you to take the path of the first reaction. To that end, we appreciate your questions and comments. Please give us your thoughts on PPLI international asset structuring.

by Michael Malloy, CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #PPLI #privateplacement #lifeinsurance #advancedfinancialsolutions

Q & A – PPLI for Wealthy International Families

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Questions and Answers from the book “The Wit and Wisdom of Professor PPLI: How to Achieve Exceptional Asset Structuring with Private Placement Life Insurance”

~ by Michael Malloy, CLU TEP RFC

Get the book now!

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PPLI for Wealthy International Families

– Including Wealthy U.S. Families

PPLI’s Beautiful Architecture

Part 3

Professor PPLI, in this Part we have a discussion of light and dark from different perspectives. How can this be relevant to PPLI asset structuring?

Imagine a typical flowchart that is used to depict a PPLI asset structure. On most flowcharts of this type, the PPLI policy box is located in the middle. Usually the owner, most often a trust, is above the PPLI policy box, and below are the various assets and holding companies necessary to complete the structure.

Let us now hear from physicist, Julian Scudder,

“Stars form light as a byproduct of the incredible pressures at their centers…. New stars only unveil themselves to our eyes by using the light they give off to burn away the dust and gas that hid them in darkness.”

Now back to our flowchart. Think of the PPLI policy box as a star at the center of the asset structure. The pressure in our analogy is the well-established insurance laws and regulations throughout the world which make these structures possible.

This PPLI policy box, now a newly formed star, gives off light to the other elements of the structure like the trust, assets, and beneficiaries so they can shine forth. All the elements then have the light they need to make the entire structure successful. This brings to mind the subtitle of our Part, PPLI’s Beautiful Architecture.

Professor PPLI, why did you include U.S. families in the title along with international families? Aren’t there domestic U.S. policies that can serve their needs?

If all a family’s assets are located in the U.S., they might consider using a U.S. product, but most often this would not work if they had unusual asset classes. Domestic U.S. PPLI companies structure their products as extensions of the standard retail Variable Universal Life products.

In most cases, a family is much better off using an offshore insurance company with a 953(d) election. Not only are fees lower, but the entire structure will put most families closer to their ultimate goal–to achieve the six elements of Expanded Worldwide Planning (EWP): privacy, asset protection, tax shield, succession planning, compliance simplifier, and trust substitute.

In our first answer we made an analogy between PPLI and the physical aspects of a star as it relates to light. Many advisors would find this analogy far fetch as most international tax advisors have little or no knowledge of the asset structuring possibilities of PPLI. Professor PPLI, please expand on this fact for us.

Quite true indeed. Attorneys, trust officers, and accountants are not offered any courses in PPLI asset structuring in their formal education, so they must encounter this outstanding tool later in their practices. Even when they do, they frequently reject it, because they are unaware of this variety of life insurance and equate PPLI with retail products.

This is not helped in the U.S. where a few major insurance companies do offer PPLI, but it is more of an extension of their retail products, as we mentioned in the second answer.

It takes a creative partnership between the various disciplines involved in a PPLI structure to accomplish the magic. When attorneys, asset managers, trust officers, accountants, and insurance advisors truly understand the dynamic asset structuring elements of PPLI, they can ride the exciting wave of what we call in the book the Unifying Factor.

Currently, when the very concept of wealth seems under attack from political parties, governments hungry for tax dollars, and worldwide governing bodies like the OECD, why not embrace the Unifying Factor. Families then can avail themselves of the six principles of Expanded Worldwide Planning (EWP) that we mentioned earlier. At Advanced Financial Solutions Inc., we endeavor to secure the Unifying Factor for each of our clients.

by Michael Malloy, CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #PPLI #privateplacement #lifeinsurance #advancedfinancialsolutions

Q & A – Elegant Simplicity Revealed

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Questions and Answers from the book “The Wit and Wisdom of Professor PPLI: How to Achieve Exceptional Asset Structuring with Private Placement Life Insurance”

~ by Michael Malloy, CLU TEP RFC

Get the book now!

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Elegant Simplicity Revealed

The PPLI Insurance Code

Part 2, Section 2

Professor PPLI, there is an ironic challenge in presenting PPLI to families. Sometimes there is initial resistance because of a family’s previous experience involving life insurance. But in the end, when the family understands all the benefits of PPLI, they frequently say, “This sounds too good to be true.”

In this section of the book we quote Albert Szent-Gyorgyi, a Hungarian biochemist,

“A discovery is said to be an accident meeting a prepared mind.”

At Advanced Financial Solutions Inc., our approach is to give the basics of Private Placement Life Insurance, (PPLI), then, have the family “discover” it themselves through their questions. This approach is also more interactive, and is not just a one-sided lecture.

PPLI works somewhat differently throughout the world, and family’s initial perceptions about life insurance differ. In the Far East, life insurance is looked upon as a favorable and conservative financial instrument. In the U.S., those who offer securities frequently position the investments in opposition to life insurance, hence, there might be a less favorable initial perception.

Whatever the perception of life insurance throughout the world, countries like Bermuda and Barbados have crafted their laws in order to have state of the art PPLI policy features. In most jurisdictions in the world, this allows clients with proper structuring the ability to place almost any of their worldwide assets inside a PPLI policy to achieve the maximum amount of privacy, tax efficiency, and asset protection.

Private letter rulings issued by the IRS in the U.S. form a significant body of knowledge that must be understood to properly construct a policy for those with a connection to the U.S.. Professor PPLI, please comment further on this.

Particularly in reference to investor control issues, the revenue rulings that you mentioned are of significance. We list them in this Section of the book.

Investor control is a large subject, so I will give you a few fairly recent items of interest on the subject. From the much cited Webber case, I find this point worth mentioning from the judge in the case, Judge Lauber:

“The ability to choose among broad, general investment strategies such as stocks, bonds or money market instruments, either at the time of initial purchase or subsequent thereto, does not constitute sufficient control over individual investment decisions so as to cause ownership of the private mutual fund shares to be attributable to the policyholders.”

One simple planning technique to shield the wealthowner from investor control is to use a non-grantor trust, and not a grantor trust to own the policy. In most situations, investor control issues pertain to the owner of the policy, and if the wealthowner is not the grantor of the trust, and the trustee of the non-grantor trust makes the investment decisions, the wealth owner is further insulated from investor control issues.

The 7702(g) variety of PPLI has become more popular of late, in part, because of the large premiums families are contributing to policies. On a traditional policy design, this usually means a correspondingly large death benefit for the policy. On a 7702(g) policy, the death benefit component of the policy is usually only 5% of the total assets contributed to the policy, and the policy owner does not have access to the growth of the cash value, during the life of the insured person of the policy. This fact eliminates the constructive receipt element of the investor control theory, as the growth in the cash value passes as a tax-free death benefit at the death of the insured person of the policy. This is just another reason to employ this type of policy design for wealthy families throughout the world.

Attempting to make something that is complex, like the tax code, simple, often results in something that becomes even more complex. This phenomenon is frequently seen in tax legislation throughout the world. This is well stated by a tax law professor in this section of the book. Professor PPLI, what are your thoughts on this subject?

Emily Cauble, Professor of Law at DePaul University, tells us,

“Simplification of tax law is complicated. Yet, political rhetoric surrounding tax simplification often focuses on simplistic, superficial indicators of complexity in tax law such as word counts, page counts, number of regulations, and similar quantitative metrics. This preoccupation with the volume of enacted law often results in law that is more complex in a real sense.”

Why not work with a structure like life insurance, that is inherently simpler and more universally established throughout the world than the shifting sands of the world’s tax codes? Yes, is most definitely our answer at Advanced Financial Solutions.

Some of you might be saying, “Well, this sounds good, but have you ever tried to figure out a life insurance policy? Isn’t it just as complex?” This is very true of most retail insurance policies that have a cash value. Not so with PPLI, which can be illustrated on a simple Excel spreadsheet. Fees are also very low in comparison, and the life insurance component is institutionally priced.

Leonardo da Vinci tells us that “simplicity is the ultimate sophistication.” At Advanced Financial Solutions Inc., we employ this concept in both our PPLI designs and working with families throughout the world.

by Michael Malloy, CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #PPLI #privateplacement #lifeinsurance #advancedfinancialsolutions

Q & A – Fence = Privacy…Well Sort of

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Questions and Answers from the book “The Wit and Wisdom of Professor PPLI: How to Achieve Exceptional Asset Structuring with Private Placement Life Insurance”

~ by Michael Malloy, CLU TEP RFC

Get the book now!

See original article

Fence = Privacy…Well Sort of

Let PPLI Be Your First Defense

Section 2, Part 1

When it comes to the six principles of Expanded Worldwide Planning (EWP), few asset structuring tools work as well as PPLI for wealthy families throughout the world. Professor PPLI, how did this come to be?

You might describe this occurrence as a happy accident. The six principles of EWP came into their own after FATCA and CRS. With these two important changes in the planning landscape, wealthy families wished a more conservative and stable method in which to organize their financial holdings. Why not use a financial tool that has been around in different forms since 100 B.C.? This is, of course, life insurance.

PPLI delivers to wealthy families all six principles of EWP: privacy, asset protection, tax shield, succession planning, compliance simplifier, and trust substitute. All these outstanding benefits in one low-cost and simple structure.

Professor PPLI, please tell us how the U.S. tax system can benefit wealthy clients throughout the world?

The tax system in the U.S. gives the individual states much independence in structuring their tax laws. In some ways, it can be compared to the cantons in Switzerland that were able to structure their laws to attract corporations from around the world to locate headquarters there. In the U.S. several states compete by designing favorable trust and tax laws that encourage wealthy families from around the world to move their financial assets to these states.

These states are most notable: South Dakota, Nevada, Delaware, Wyoming, and recently New Hampshire. In general the U.S. gives families stability with a strong rule of law that protects personal property. Also, since the U.S. is not a party to CRS there is limited reporting. With the favorable laws in these states coupled with a PPLI policy, the family has an excellent home for its worldwide holdings.

At Advanced Financial Solutions almost all our PPLI policies involve some sort of cross border situation. Professor PPLI, please tell us how these cross border planning situations are best approached.

Throughout the world governments pass new tax laws daily and its citizens and those who come under its jurisdiction must comply with these laws, or face certain penalties. Also, tax laws change frequently and how you must comply does not always translate into a simple answer or number on your tax return.

This is why at Advanced Financial Solutions Inc., we thoroughly research our PPLI structures, and make sure they comply with all the tax authorities involved in the locations of a client’s assets. Because a properly structured PPLI policy can hold almost any asset, this thorough research must be specific to the laws pertaining to this asset class.

For instance, some clients might wish to invest in an Australian security, or others have a private jet registered in a specific jurisdiction. We undertake this research at the beginning of the policy design to insure that it is fully compliant. Even operating businesses can be placed inside a PPLI policy with the proper structuring. This is all part of our unique method of asset structuring for wealthy families throughout the world.

by Michael Malloy, CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #PPLI #privateplacement #lifeinsurance #advancedfinancialsolutions

Let PPLI Lead the Charge

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The Highest Form of Zero

Part 5

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Our next few articles will comprise an in-depth look at the five main components of our PPLI Concept Map: Professor PPLI Defines Nothing. We also offer you the fifth part of, “She Was Good For Nothing,” by Hans Christian Andersen. This charming fairy tale supports our theme of nothing.

The potential of Private Placement Life Insurance (PPLI) as an asset structuring tool for wealthy families has barely been explored. Particularly in a U.S. context, one sees PPLI’s unique traits expressed in numbers, mainly through the compounding of the tax-free growth of its cash value over time. Yes, this is most true and correct, but this is only the beginning of the story.

Just as “the cloud” has taken our data storage to a new level, this article will endeavor to raise your awareness of the myriad possibilities of PPLI for structuring the worldwide assets of wealthy families. This is expressed excellently in the Senior Consultant, The Voice of the Investment Management Consultant.

“Private Placement Life Insurance (PPLI) is much more than an insurance policy. PPLI represents one of the most powerful vehicles available to the high net worth investor in the marketplace today.

PPLI enhances both wealth creation and wealth preservation. Wealth creation is the result of the tax-free growth of the assets in the insurance contract. Wealth preservation is a result of the death benefit paid from the insurance contract.”

Here are a few examples where Advanced Financial Solutions was able to assist wealthy international families.

PPLI Solution A, by Advanced Financial Solutions Inc.

A Chinese client, who is a U.S. green card holder residing in Hong Kong, had pre-IPO stock valued at $10M. Upon going public, it was estimated that the stock will be worth many times this valuation. Through the use of careful planning, we were able to place the stock into a properly structured PPLI policy before the stock went public, thus saving the client $45M in U.S. capital gains tax. He was able to diversify his holdings inside the policy tax-free, and pass his estate tax-free to his heirs. The client accessed the funds inside the policy through low-cost policy loans.

PPLI Solution B

A Chinese family came to us for succession planning for offshore companies owned by the family. They wished to pass these offshore companies located in various parts of the world to their son, who is a green card holder residing in the U.S. Besides transferring the companies at the death of the wealth owner via a properly structured PPLI policy, the son wished to take the profits from the companies and invest them in real estate projects outside the U.S. We created a PPLI structure for the family that accomplished all of these aims. The PPLI structure also gave them tax-deferral on all the future revenue from the companies.

PPLI Solution C

An Israeli client who resides in Italy has a company where all the revenue is generated in Italy. He is also a U.S. green card holder, but spends very little time in the U.S. He had a Nevada company that did the processing of his customers’ orders which came from customers worldwide. The client wished to restructure to lessen his U.S. tax burden which we accomplished for him using a 953(d) offshore PPLI policy.

PPLI Solution D

A young entrepreneur with worldwide holdings in sports, natural resources, gaming, and content management wishes us to check his compliance with FATCA and CRS. He is a U.S. green card holder as well as a UK resident, and citizen of an African country. He had created a dozen companies with excellent potential. We brought him into compliance with tax authorities worldwide with a PPLI structure. We gave his revenues a boost, because in the PPLI structure all the profits become tax-deferred. We protected his family with the low-cost death benefit of the PPLI policy.

We conclude our theme of Nothing by defining it with a Dutch concept, niksen from Olga Mecking in the New York Times article, “The Case for Doing Nothing, Stop being so busy, and just do nothing. Trust us.”

“Running from place to place and laboring over long to-do lists have increasingly become ways to communicate status: I’m so busy because I’m just so important, the thinking goes.

Perhaps it’s time to stop all this busyness. Being busy — if we even are busy — is rarely the status indicator we’ve come to believe it is. Nonetheless, the impact is real, and instances of burnout, anxiety disorders and stress-related diseases are on the rise, not to mention millennial burnout.

There’s a way out of that madness, and it’s not more mindfulness, exercise or a healthy diet (though these things are all still important). What we’re talking about is … doing nothing. Or, as the Dutch call it, niksen.

What is niksen?

It’s difficult to define what doing nothing is, because we are always doing something, even when we’re asleep.

Doreen Dodgen-Magee, a psychologist who studies boredom and wrote the book “Deviced! Balancing Life and Technology in a Digital World,” likens niksen to a car whose engine is running but isn’t going anywhere.

“The way I think about boredom is coming to a moment with no plan other than just to be,” she said.

Sandi Mann, a psychologist at the University of Central Lancashire in Britain, added that niksen can be “when we’re not doing the things we should be doing. Because perhaps we don’t want to, we’re not motivated. Instead, we’re not doing very much.”

More practically, the idea of niksen is to take conscious, considered time and energy to do activities like gazing out of a window or sitting motionless. The less-enlightened might call such activities “lazy” or “wasteful.” Again: nonsense.”

Part 5 of “She Was Good For Nothing” by Hans Christian Andersen:

“It was just then that my darling boy, who lies sleeping there, was born. Then his father had a long and severe illness, and for nine months I even had to dress and undress him every day. We kept on going backward. We had to borrow more and more; one by one all our possessions were sold; and at last Erik died. Since then I have worked and slaved for the boy’s sake, have gone out scrubbing floors and washing linen, done coarse work or fine, whatever I could get. But I was not to be better off; it is the Lord’s will! He will take me away and find better provisions for my child.” Then she fell asleep.

In the morning she seemed better and decided she was strong enough to return to her work. But the moment she felt the cold water a shivering seized her; she grasped about convulsively with her hands, took one step forward, and fell. Her head lay on the dry bank, but her feet were in the water of the river; her wooden shoes, in each of which there was a handful of straw, were carried away by the current.

And here she was found by Maren, when she came to bring her some coffee.

A message had come to her lodging that the Mayor wanted to see her, for he had something to say to her. It was too late. A doctor was summoned; the poor washerwoman was dead.

“She has drunk herself to death,” said the Mayor.

The letter that had brought the Mayor the news of his brother’s death also gave a summary of his will, and among other bequests he had left six hundred dollars to the glovemaker’s widow, who had formerly served his parents! The money was to be paid at discretion in large or small sums to her and her child.

“There was some nonsense about love between my brother and her,” said the Mayor. “It’s just as well she’s out of the way. Now it will all come to the boy, and I’ll place him with some honest people who will make him a good workman.” And on these words our Lord laid his blessings.

And the Mayor sent for the boy, promised to take care of him, and told him it was a lucky thing his mother was dead; she was good for nothing.

They carried her to the churchyard, to a pauper’s grave. Maren planted a little rose tree on her grave, while the boy stood beside her.

“My darling mother,” he said as the tears started from his eyes. “Is it true that she was good for nothing?”

“No, it is not true!” said the old woman, looking up to heaven. “I have known it for many years and especially since the night before she died. I tell you she was a good and fine woman, and our Lord in heaven will say so, too, so let the world say: ‘She was good for nothing!’ “

We wish to take you to the highest level of Expanded Worldwide Planning through careful research of your unique family situation. Please let us begin the process by contacting our office today for a gratis initial consultation to find out if our advanced PPLI structuring methods align with your financial goals.

by Michael Malloy, CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #PPLI #privateplacement #lifeinsurance #advancedfinancialsolutions

Ancient Wisdom and PPLI

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Socrates and King Lear Teach Us a Lesson

Part 4

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Our next few articles will comprise an in-depth look at the five main components of our PPLI Concept Map: Professor PPLI Defines Nothing. We also offer you over the next five Parts, “She Was Good For Nothing,” by Hans Christian Andersen. This charming fairy tale supports our theme of nothing.

We introduce examples from ancient history and literature, ancient wisdom, to explain how PPLI can be a perfect fit for international families who seek privacy, tax efficiency, and asset protection. PPLI works excellently in multi-jurisdictional planning for those families seeking domiciles outside their home countries for political and economic reasons.

It is interesting to note that both Socrates and Shakespeare’s King Lear were in a sense exiled in their own kingdoms. Socrates put to death by state officials in Athens, and King Lear left to wander in his own country after political intrigue forced him out. These are highly charged dramatic events. It is sometimes equally so for wealthy international families. More about Socrates and King Lear later in our article.

An article in International Advisor, “Who is advising Asia’s ultra wealthy?” by Kirsten Hastings focuses on the role of independent asset managers (IAMs). IAMs are key players in the team that we assemble to achieve a properly structured PPLI policy. Frequently there are multiple IAMs on our teams to accommodate the many asset classes that become part of the PPLI policy. Here are some highlights from this article.

“Wealth in Asia is rising faster than in any other part of the world, meaning that increasing numbers of incredibly rich people need expert advice.

These ultra-high net worth individuals can be beyond the reach of financial advisory and wealth management firms.

And rather than turn to private banks, many are seeking the services of independent asset managers (IAMs).

Also known as external asset managers (EAMs), they have a long history in Europe and the US but were a rarity across Asia as recently as 10 years ago.

The Association of Independent Asset Managers (AIAM) was founded in Singapore in 2011 and only opened in Hong Kong in 2015.

So, what do they do?

Independent asset management involves a client opening an account with a custodian bank, which may be a private bank, and placing assets in the account, according to a 2018 report from recruitment specialists Selby Jennings.

The client then gives the IAM authority and power of attorney as a third party to represent them in managing the investment portfolio and asset allocation.

The assets remain in an account in the client’s name at all times, but the IAM makes decisions on how the assets should be managed.

In addition to investment advice, IAMs also offer tax and succession planning along with a host of other, very bespoke services.

With the high net worth population of the region set to increase by over 40% every year over the next decade, the number of IAMs is also projected to increase – by 25% in Singapore and 50% in Hong Kong, Selby Jennings added.

Insurance and IAMs

“IAMs are starting to realise that the investment returns they generate for their clients could be wiped out by market volatility or different taxes when rebalancing the portfolio or realising the gains.”

He said they are increasingly exploring the functions of insurance to “supplement their client’s planning”.

“Due to the complex needs of the high net worths and global tax frameworks, we see a lot of IAMs are considering different wealth structures like PPLI (private placement life insurance) and are exploring insurance as an asset class.””

International Life Insurance

In keeping with our cross-border and international theme, we quote from International Life Insurance edited by David D Whelehan, JD in the chapter, “International Life Insurance An Overview.”

“This product is for the wealthy, “accredited” investor. They are usually very large single premium structures. It is classified more as an institutional product, as the charges and fees are quite low in comparison to retail products described above. Another advantage is investment flexibility as they generally can be invested in things not permitted in a general account retail product, like hedge funds and private equity.

Premiums and benefits can also be paid in “kind,” as opposed to in cash. In addition, the policyowner can select his, or her, own Investment Manager for just the single policy to invest according to the policyowner’s general directions. The Custodian of the underlying assets in the fund can also be selected by the policyowner. Private placement products are tailored to meet specific objectives of the client, but are carefully designed to be compliant with local tax laws, so as to enjoy the tax treatment desired.”

Socrates Ignorance

Garth Kemerling’s insightful commentary in the Great Philosophers series gives us an excellent interpretation of what Socrates means by one of his most famous quotes, “I only know that I know nothing.”

“It is important to note that Socrates himself did not claim to know better than others. He frequently emphases that he is ignorant of the answer. The importance of this helps to draw the line between dogma and genuine philosophy. It is one thing to state one’s opinion of how things are and should be. Powerful institutions such as religions and political systems are built upon such dogmas and the demands that others abide by them. Socrates, on the other hand, started from a position of ignorance and sought the truth. In the end, he has no dogmatic program for us to follow, just a method for seeking the truth for ourselves, without any guarantee that we will find it. Philosophy as practiced by Socrates is an open system.

When he finds that the experts are just as ignorant about what things really are, he reasons: “I do not suppose that either of us knows anything really beautiful and good, I am better off then he is – for he knows nothing, and thinks that he knows. I neither know nor think that I know.” Socrates concludes that it is better to have ones ignorance tan self-deceptive ignorance. Socrates may not know the ultimate answers to the questions he raises, but he knows himself. It is this self-knowledge and integrity that constitutes the wisdom of Socrates. The open invitation is for all of us to ask ourselves how much we truly know of what we claim.”

Part 4 of “She Was Good For Nothing” by Hans Christian Andersen:

“After he had gone my mistress called me in to speak to me; she looked so grave and yet so kind, and spoke as wisely as an angel indeed. She pointed out to me the gulf of difference, both mentally and materially, that lay between her son and me. ‘Now he is attracted by your good looks, but that will fade in time. You haven’t received his education; intellectually you can never rise to his level. I honor the poor,’ she continued, ‘ and I know that there is many a poor man who will sit in a higher seat in the kingdom of heaven than many a rich man; but that is no reason for crossing the barrier in this world. Left to yourselves, you two would drive your carriage full tilt against obstacles, until it toppled over with you both. Now I know that Erik, the glovemaker, a good, honest craftsman, wants to marry you; he is a well-to-do widower with no children. Think it over!’

“Every word my mistress spoke went through my heart like a knife, but I knew she was right, and that weighed heavily upon me. I kissed her hand, and my bitter tears fell upon it. But still bitterer tears fell when I lay upon my bed in my own room. Oh, the long, dreary night that followed-our Lord alone knows how I suffered!

“Not until I went to church on Sunday did peace of mind come after my pain. It seemed the working of Providence that as I left the church I met Erik himself. There were no doubts in my mind now; we were suited to each other, both in rank and in means; he was even a well-to-do man. So I went straight up to him, took his hand, and asked, ‘Do you still think of me?’

” ‘Yes, always and forever,’ he said.

” ‘Do you want to marry a girl who likes and respects you, but does not love you?’

” ‘I believe love will come,’ he said, and then we joined hands.

“I went home to my mistress. The gold ring that her son had given me I had been wearing every day next to my heart, and every night on my finger in bed, but now I drew it out. I kissed it until my lips bled, then gave it to my mistress and told her that next week the banns would be read for me and the glovemaker.

“My mistress took me in her arms and kissed me; she didn’t say I was good for nothing, but at that time I was perhaps better than I am now, for I had not yet known the misfortunes of the world. The wedding was at Candlemas, and for our first year we were quite happy. My husband had a workman and an apprentice with him, and you, Maren, were our servant.”

“Oh, and such a good mistress you were!” said Maren. “I shall never forget how kind you and your husband were to me!”

“Ah, but you were with us during our good times! We had no children then. I never saw the student again. Oh, yes, I saw him once, but he didn’t see me. He came to his mother’s funeral, and I saw him standing by her grave, looking so sad and pale-but that was all for his mother’s sake. When his father died later he was abroad and didn’t come to that funeral. He didn’t come here again; he became a lawyer, and he never married, I know. But he thought no more of me, and if he had seen me he would certainly have never recognized me, ugly as I am now. And it is all for the best!”

Then she went on to tell of the bitter days of hardship, when misfortune had fallen upon them. They had saved five hundred dollars, and since in their neighborhood a house could be bought for two hundred, they considered it a good investment to buy one, tear it down, and build again. So the house was bought, and the bricklayers and carpenters estimated that the new house would cost a thousand and twenty dollars. Erik had credit and borrowed that sum in Copenhagen, but the captain who was to have brought the money was shipwrecked and the money lost.”

Both Socrates and King Lear ended their lives tragically, yet were both noble in spirit. Socrates accepted his death in an herotic fashion. Lear was reunited with his daughter, Cordelia, yet they died in the confusion of battle between the warring parties at the end of the play. How is this related to PPLI?

Great art strives to ennoble us. This is why it is great, and rises above mere entertainment. At Advanced Financial Solutions our aim is to rise to the highest level of structuring for wealthy international families, giving both maximum privacy, and compliance with tax authorities worldwide.

Our quest is not outwardly considered art, but inwardly its goal is the same–uncompromising excellence. We invite you to partake of this excellence by contacting us today to find out if PPLI structuring is right for you.

by Michael Malloy, CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #PPLI #privateplacement #lifeinsurance #advancedfinancialsolutions

Fostering Discipline Is Paramount

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PPLI Joins ‘Two Sides of the Same Coin’

To be thorough and open to new possibilities at the same time requires discipline: embracing ‘two sides of the same coin.’ In the PPLI structuring of wealthy international families’ assets, Advanced Financial Solutions, Inc. strives to achieve this aim. For each new case we exam similar PPLI cases that we have handled in the past. For the specific knowledge that we will need for new cases which we might lack, we have an excellent resource of professional advisors worldwide that can be easily contacted to supply this missing knowledge for a successful PPLI structure to be created.

For our analogous examples we have one from the area U.S. tax planning and how it affects U.S. beneficiaries of Foreign Grantor Trusts, and strangely enough, one from high-fashion. This example shows us what happens when the ‘two sides of the same coin’ turn out to be the same thing, and–to change this analogy–the coin loses its luster by turning out to be a copy. In a humorous vein, you can view this also as social media bringing transparency to haute couture.

Before we share the above material, we are pleased to give you this description of PPLI from International Life Insurance edited by David D Whelehan, JD in the chapter, “International Life Insurance An Overview.”

“This product is for the wealthy, “accredited” investor. They are usually very large single premium structures. It is classified more as an institutional product, as the charges and fees are quite low in comparison to retail products described above. Another advantage is investment flexibility as they generally can be invested in things not permitted in a general account retail product, like hedge funds and private equity.

Premiums and benefits can also be paid in “kind,” as opposed to in cash. In addition, the policyowner can select his, or her, own Investment Manager for just the single policy to invest according to the policyowner’s general directions. The Custodian of the underlying assets in the fund can also be selected by the policyowner. Private placement products are tailored to meet specific objectives of the client, but are carefully designed to be compliant with local tax laws, so as to enjoy the tax treatment desired.”

In the STEP Journal Melvin A Warshaw and Lawrence M Lipoff discuss a key change to the US Tax Cuts and Jobs Act of 2017, and assess what it means for advisors to trustees of foreign grantor trusts. They conclude that due to recent changes in U.S. tax law that a properly structured PPLI provides an excellent solution for U.S. beneficiaries of foreign grantor trusts.

A Simpler and Safer Strategy

“In a previous two-part article,^[1] we presented US tax advisors with our highly technical analysis of a key change in the foreign tax provisions of the US Tax Cuts and Jobs Act of 2017 (the Act) impacting how trustees of foreign grantor trusts (FGTs) traditionally hold US-situs portfolio assets that potentially benefit both US and non-US heirs of a non-citizen, non-resident (NCNR) of the US.”

Trustees must analyze whether their existing single foreign corporation (FC) strategy is still viable and, if not, what steps they should take to address this US tax law change. Some advisors suggest a second FC and others a two-tier or three-tier FC structure. Leaving aside that planning variations relying on different entity structures may be one option, we believe that offshore^[2] private placement life insurance (PPLI) may offer a far simpler and safer strategy.

Under pre-2018 US tax law, trustees of FGTs generally relied on a single non-US holding company to shield the NCNR grantor of an FGT from US estate tax on US-situs portfolio assets. Following the death of the NCNR, the trustees would effectively eliminate this FC by filing a post-death, retroactive (so-called ‘check-the-box’) election within 30 days of such death. Gain recognition would be avoided on the historical pre-death unrealised appreciation of the US portfolio assets, prior to elimination, i.e. liquidation, of the FC, as well as pre-2018 controlled foreign corporation (Subpart F CFC) passive income tax and related tax compliance. Plus, the US heirs would achieve a basis step-up in the underlying US portfolio assets equal to their fair market value (FMV) on the date of the election.

The Act repealed the 30-day retroactive election for tax years after 2017. Under current US tax law, a post-death ‘check-the-box’ election for the trust’s FC could cause US beneficiaries of the trust to inherit the historical pre-death unrealised appreciation in the US-portfolio assets and incur cumbersome US tax compliance. Further, if an FC is a CFC for even one day during the tax year, there could be potential phantom income for the US beneficiaries of the trust now encompassing the new US ‘global intangible low taxed income’ (GILTI) regime.

Continuing a single FC

The single FC structure continues to be effective in preventing imposition of US estate tax on the US portfolio assets held by the FC. If most of the NCNR’s trust beneficiaries are US persons (citizens or residents),^[3] the trustees and US advisors must anticipate that there will now be US income tax and US tax reporting on historical appreciation of the assets held in the single FC that would eventually be recognised by the US beneficiaries after the NCNR’s death. If most of the trust beneficiaries are not US persons, it may be possible that the single FC will lack sufficient beneficial ownership by US persons to qualify as a CFC.

Side-by-side FCs

Another approach suitable for families with both US and non-US persons as beneficiaries is to have the trustees of the FGT create a second FC, which would own only non-US-situs assets. The original FC would own only US securities. The non-US portfolio assets owned by the second FC would be earmarked to benefit solely non-US persons as trust beneficiaries after the death of the NCNR. The US portfolio assets owned by the existing FC would be earmarked for the US beneficiaries. There would be no US estate tax on the non-US assets owned by the second FC. A retroactive check-the-box election could be filed for this second FC effective on the day before the NCNR’s death.

Some US advisors advocate relying exclusively on entity structuring to convert a single FC into a multi-tier FC structure involving at least three FCs. Prior to the NCNR’s death, the trustees of the NCNR’s FGT would create two FCs. These two FCs would then together equally own the shares of a third lower-tier FC. The US portfolio assets would be owned by the lower-tier FC. Following the death of the NCNR, the lower- and upper-tier FCs would be deemed liquidated for US tax purposes (by filing check-the-box elections) in a carefully scripted sequence as follows.

First, the upper-tier FCs would each file a check-the-box election for the lower-tier FC, effective one day prior to the death of the NCNR. This results in a taxable liquidation of the lower-tier FC without current US income tax on the historical pre-liquidation unrealised appreciation inside the FC. However, the upper-tier FCs’ basis in the underlying US securities held by the former lower-tier FC will equal the FMV of such assets on the date of the deemed liquidation of the lower-tier FC.
Second, two days after the NCNR’s death, both upper-tier FCs will make simultaneous check-the-box elections. The inside basis of the US portfolio assets previously held by the lower-tier FC prior to its deemed taxable liquidation would be stepped up or down to the FMV of such assets on the day after the death of the NCNR.

Advocates of this highly complicated, carefully scripted entity structure and serial liquidation strategy for US portfolio assets indicate that, if successful, the results should be comparable to the results under prior law. However, this is not without some new tax and reporting risks, as noted above, nor does it address the question of what the independent significant non-tax business purpose for ‘each’ of the three FCs would be.

Offshore PPLI

Assuming the NCNR is insurable, advisors should seriously consider the possibility of their NCNR clients, with significant US portfolio assets, and US persons as potential beneficiaries investing in certain types of offshore PPLI policies that in turn invest in US assets.

Purchasing an offshore US tax-compliant PPLI policy will result in no US income tax recognition in the annual accretion in the cash value growth of the policy. Holding the policy until death is equivalent to receiving a US basis step-up at death on the death benefit that is payable in cash. In planning for the US beneficiaries of the NCNR, if the revocable FGT were named as owner and beneficiary of the PPLI, this trust could be structured to pour over at the death of the NCNR to a US dynasty trust organised in a low-tax jurisdiction with favourable state trust laws. This structure will ensure that the death benefit pours over to a US domestic trust that will not become subject to foreign non-grantor trust (FNGT) tax rules.

A non-admitted offshore carrier obviates CFC status for the policy and policy owner by making a certain special US tax code (s.953(d)) election to be treated as a US domestic carrier. Aside from avoiding CFC status for the policy and its owner, making this special election causes the carrier to absorb US corporate income tax and administrative costs to comply with US informational tax reporting. The hidden benefit of an offshore carrier making this special US tax election is that it enables such a carrier to claim a special deduction of reasonable reserves required to satisfy future death benefits. The offshore carrier simply absorbs the cost of US income tax compliance including its responsibility for CFC and passive foreign investment company (PFIC) reporting. There is no look-through of an insurance policy to its owner for the purposes of applying the PFIC rules. So long as the NCNR avoids any control over the selection of specific investments made by the policy owner for the policy, investor control should not be a concern.

Our conclusion is that current US tax law provides clear support for the proposition that the PFIC and CFC rules should not apply to a US tax-compliant policy issued by a foreign carrier that files a special (s.953(d)) election with the Internal Revenue Service. This will result in the tax-free inside growth in the PPLI policy that, if held until the death of the NCNR, will result in no income tax on the death benefit. We believe that purchase of an offshore PPLI policy by the NCNR through an FGT that pours over to a US dynasty trust is an efficient, safe and simple solution that allows an NCNR to invest in US portfolio assets, and leverages that investment and all subsequent growth tax-free into policy death benefit available to US beneficiaries after such death.”

From the Wall Street Journal, we share “Fashion Industry Gossip Was Once Whispered. Now It’s on Instagram” by Ray A. Smith.

“Shortly after designer Olivier Rousteing showed his fashion collection for Balmain in Paris last September, French designer Thierry Mugler posted on Instagram.

Mr. Mugler, famous in the 1980s and early ’90s for power suits and the George Michael “Too Funky” video, posted a series of side-by-side images comparing his past ensembles to Mr. Rousteing’s new looks. Next to a Balmain black, one-shouldered jacket-dress with white lapels, Mr. Mugler posted his own similar design from 1998 with the comment: “Really?”

Along with Balmain’s dress featuring a graphic, webbed print, Mr. Mugler, who now goes by the first name Manfred, attached his own webbed design from 1990. “No comment!”

The episode surprised Mr. Rousteing. “Oh my God, I’m so sorry for him, seriously,” said 33-year-old Mr. Rousteing about 69-year-old Mr. Mugler in an interview. He denied copying the designer.

In the past, copycat allegations rarely reached beyond fashion industry gossip—or sometimes courtrooms—and rarely made it to the wider public. Now with Instagram, fashion’s favorite app, accusations spread much faster and to a wider audience. Eagle-eyed accusers can post comparison pictures and add arrows and circles to zero in on the alleged offense immediately after a fashion show, now that runway images are beamed out in real time.

High-end fashion labels are increasingly being called out on social media for copying other designers or designs, leading to back-and-forth exchanges, lawsuits and expensive apologies.

Instagram accounts, including Diet Prada, have formed to focus on designers and retailers whose creations some feel look too much like other designers’ past work. Since its 2014 launch, Diet Prada, which isn’t affiliated with Prada, has amassed more than 960,000 followers. The Fashion Law blog and CashinCopy Instagram feed also name and shame copying.”

If you are looking for a bespoke solution to your asset structuring needs, we welcome you to contact us. You will also benefit from our conservative and fully compliant methodology of using PPLI as the centerpiece of the structure. You will be pleasantly surprised to experience ‘two sides of the same coin.’

^[1] M. A. Warshaw and L. M. Lipoff, ‘How to Navigate the Choppy Seas for Foreigners With U.S.-Based Heirs: Part I’, Trusts & Estates (June 2018), and ‘Non-Citizen, Non-Resident Options for Life Insurance’, Trusts & Estates (August 2018)

^[2] All uses of ‘offshore’ and ‘foreign’ are given from the perspective of the US.

^[3] All references to ‘US persons’ in this article refer to citizens and residents only.

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by Michael Malloy CLU TEP RFC, @ Advanced Financial Solutions, Inc

#michaelmalloy #michaelmalloysolutions #advancedfinancialsolutions #ppli