PPLI Offers the Following Advantages
- Adds ease of reporting to tax authorities
- Adds straightforward administration of assets
- Adds commercial substance to structures
Compliance Simplifier
The beneficial owner of the assets in a properly structured PPLI policy is the insurance company.1 This greatly simplifies any reporting obligations to tax authorizes, because the assets inside the policy are held in segregated accounts, and frequently spread out over multiple jurisdictions worldwide. The PPLI insurance company becomes the administrator of the assets and their beneficial owner. Because they are held in segregated accounts, they are not part of the insurance company’s balance sheet and are often placed in the hands of a custodian bank.2
Most PPLI companies will accept any qualified institution to act as custodian, and any qualified asset manager to direct the investments in the segregated accounts. This relationship between the owner of the policy, the insurance company, and the segregated accounts is codified in the laws of the various jurisdictions where PPLI insurance companies are located, and therefore lends viable commercial substance to such a structure.
Endnotes
- “Wikipedia Private placement life insurance,” https://en.wikipedia.org/wiki/Private_placement_life_insurance see also, “The New Age of Global Tax Transparency and Registers of Beneficial Owners. The Compliant Solution,” Taxlinked.net https://taxlinked.net/getattachment/m/FT-Alternative-Solutions/Publications/The-New-Age-of-Global-Tax-Transparency-and-Registe/The-New-Age-of-Global-Tax-Transparency-and-Registers-of-Beneficial-Owners-(3).pdf
- Bortnick, “Tax Management: Building Wealth, Reducing Taxes,” in The PPLI Solution, Delivering Wealth Accumulation, Tax Efficiency, and Asset Protection Through Private Placement Life Insurance (The PPLI Solution) at 33 (Bloomberg Press, 2005).
- “Wikipedia Private placement life insurance,” https://en.wikipedia.org/wiki/Private_placement_life_insurance
by Michael Malloy CLU TEP RFC, @ EWP Financial
