Expanded Worldwide Planning (EWP)
If a tax authority wishes to tax something, two items of concern are what type of tax to apply and was the transaction done in its jurisdiction. In our internet age this is not always so easy to clarify. Our embrace of Expanded Worldwide Planning (EWP) makes this process of classification of tax and location simpler.
At the heart of EWP is a properly structured Private Placement Life Insurance (PPLI) policy. The assets inside this policy can be anything that can held by a trust company. These assets can also be located anywhere in the world. While these assets are inside this PPLI policy, all tax is deferred. At the death of the insured life/lives under the policy, these assets pass tax-free to the beneficiaries of the PPLI policy.
The news items that gave birth to our thoughts we will discuss below. But first some more about EWP and PPLI, and how it can streamline reporting obligations to tax authorities, and bypass the need to classify the type of tax that needs to be applied to the assets. As we stated above,all tax is deferred for assets inside a properly structured PPLI policy.
Further, for reporting purposes, the insurance company becomes the beneficial owner of the assets inside the policy. For clients not seeking to hide assets, but seeking legitimate privacy, this is an added bonus for using EWP.
What to tax and where it is located?
Our first news item we have quoted previously, and now use it to illustrate how a new tax entity is not so easy to fit into an existing tax code that was written before this new tax entity was even invented. The taxation of property and currency occupy different sections of a tax authorities code.
Courtesy of Mateo Jarrin Cuvi of Taxlinked.net
“Israel’s tax authorities have decided to classify Bitcoin & other cryptocurrencies as property instead of currencies. How will this affect their taxation.”
Our next quote deals with the location of the item to be taxed, and nicely illustrates how this can be challenging to governments and tax authorities.
Courtesy of Brent Kendall and Nicole Hong of the Wall Street Journal
“High Court Grapples With Case of Emails Stored Abroad”
WASHINGTON—Supreme Court justices voiced concern Tuesday that Microsoft’s resistance to U.S. search warrants for customer emails stored overseas would hamper criminal investigations, in a case that pits leading tech companies against law enforcement.
The justices were reviewing a lower-court ruling Microsoft won in 2016 that clipped the Justice Department’s authority to obtain overseas emails. The battle dates back to 2013 when the U.S. got a warrant that ordered Microsoft to hand over messages in an email account that was linked to narcotics trafficking. Microsoft argued the warrant wasn’t valid because the emails were stored in Ireland.”
Wealthy international clients are looking for simple and compliant structures that also have privacy safeguards. Using EWP with PPLI can give this to them. Please let us know how we can assist you further with using these unique and straightforward structures.
by Michael Malloy CLU TEP GRFC, @ Advanced Financial Solutions, Inc
