Tag: Michael Malloy

The 80/20 Rule

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The 20% Is Yours With PPLI

In terms of structuring assets for wealthy international families, Private Placement Life Insurance (PPLI) puts you at the top of your class.  What is top of your class? Let us apply the 80/20 rule.

Wikipedia gives us a brief history of the 80/20 rule.

The Pareto principle (also known as the 80/20 rule, the law of the vital few, or the principle of factor sparsity) states that, for many events, roughly 80% of the effects come from 20% of the causes.

Management consultant Joseph M. Juran suggested the principle and named it after Italian economist Vilfredo Pareto, who noted the 80/20 connection while at the University of Lausanne in 1896, as published in his first work, Cours d’économie politique.

Essentially, Pareto showed that approximately 80% of the land in Italy was owned by 20% of the population.

It is an axiom of business management that “80% of sales come from 20% of clients”. Richard Koch authored the book, The 80/20 Principle, which illustrated some practical applications of the Pareto principle in business management and life.

Expanded Worldwide Planning (EWP) is the overarching principle that our firm embraces that is becoming a new model for those who structure the assets of wealthy international families. If we define success as the 20% part of the 80/20 equation, what are these characteristics that assist in this success:

  • All assets inside the PPLI policy receive tax deferral, not only investments, but business income too.
  • The assets pass tax-free to the beneficiaries named in the PPLI policy. In a properly structured policy one creates a tax-free environment for these assets. Assets can be located anywhere in the world.
  • Because life insurance is used, FATCA and CRS reporting is greatly simplified, and in some cases, is eliminated.
  • Families receive enhanced privacy, because the insurance company becomes the beneficial owner of the assets inside the PPLI policy.
  • The EWP structure provides excellent asset protection.
  • The EWP structure is low cost with fees averaging 1% of assets.
  • The EWP structure is fully compliant with the tax authorities of all tax jurisdictions.
  • Should an untimely death of the wealth creator occur, his family is protected with a tax-free PPLI death benefit.

80/20 In Action

According to a recent report on CNBC, just three stocks are responsible for most of the market’s gain this year.  Amazon, Netflix, and Microsoft together are responsible for 71% of S & P 500 returns and for 78% of NASDAQ 100 returns.  Not quite 80/20, but the principal is there.

Now let see how the 80/20 plays out more personally in our daily lives. If you have had the experience of working closely with a group of people over a long period of time, you find out their strengths and weakness and your own. 

You find that that some do things well in some areas and not so well in others–and if you are honest with yourself–this applies to observations about yourself too.  So if we take the 80/20 rule as our guide, we are grouped into the 80% part or the 20% part, depending on the task or character trait that we are measuring.

Our firm must conduct diligent research to achieve the aims of the families that approach us for PPLI structuring. We must find the best possible way to give them the tax and enhanced privacy benefits that they seek. Our goal at the end of our research, is to place the family in the 20% part of the equation.

We wish to elevate you to the 20% through our rigorous and thorough PPLI structuring process. We invite you to contact us today so we can begin the process now.

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

 

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A Great Dance Couple: EWP & Trust

A Great Dance Couple: EWP & Trust

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“Dancing Cheek to Cheek”

The films of Fred Astaire and Ginger Rogers in the 1930’s and 1940s had some sensational dance routines.  The dance couple of Expanded Worldwide Planning (EWP) and a Trust are poised for equally sensational steps in the realm of planning for wealthy international families.

Our firm specializes in just this brand of choreography: using a properly structured Private Placement Life Insurance (PPLI) in combination with an excellently drafted Trust.  We capitalize Trust(s), because there is a large variety to choose from in international tax planning, and the selection depends on the nationality of the family members, their jurisdictions of domicile, the passports they carry, the location of their assets, and all the various countries’ laws that impact these items.

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.

A trust can be used in connection with other planning to lessen taxes, but by itself does not automatically confer tax advantages. For example, a trust cannot pass assets as a tax-free death benefit to future generations, as a PPLI policy can do.

For those jurisdictions in the world that recognize trust, there are innumerable techniques used by wealthy international families that favor the use of a trust.

Many advisors who draft trusts miss the opportunity of “dancing cheek to cheek” by not incorporating PPLI policies in conjunction with their trust planning.

Trust and Insurance Comparison

●    Contractually based and used by millions ●    Provides some asset protection
●    Tax deferral ●    Sometimes seen as tool for the rich
●    Insurance company is beneficial owner ●    Requires “trustee” with full control
●    Simplified or limited reporting ●    More stringent reporting requirements
●    Potentially tax free ●    Tax filings for trust and possibly beneficiaries required in some jurisdictions
●    No capital gains tax ●    Limited or not direct tax deferral on payouts
●    No trustee  
●    Asset protection  

In most civil law jurisdictions, trusts are poorly acknowledged and trust law is not well developed. This can create obstacles for those domiciled in these civil law jurisdictions that have created foreign trusts. However, in certain circumstances, a PPLI structure can circumvent these problems and achieve the planning aims one would more commonly be able to fulfill with a trust in a common law jurisdiction.

Our well-rehearsed team of advisors can truly teach you some new dance steps, that partner EWP with trusts, so “Let’s Dance.”

 

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

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Crypto, PPLO and EWP

PPLI and Cryptocurrency-Together A Winner

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Expanded Worldwide Planning (EWP) Embraces Change

Updated

Properly structured Private Placement Life Insurance (PPLI) gives the assets inside the policy tax deferred growth for the life of the policy.  When the insured life/lives under the policy pass on, the assets pass as a tax-free death benefit to the beneficiaries under the policy.  If some of the assets inside the policy are cryptocurrencies, they also receive this tax-advantaged treatment. Essentially PPLI is more of an income tax and estate tax planning tool than it is a product.  Many asset classes are supported in an open architecture EWP structure.

We will discuss some more basics on structuring with PPLI in the context of EWP, then, something more on how cryptocurrencies and PPLI both occupy a similar space on the international scene for wealthy clients.

Any asset that can be custodied by a reputable trust company can go into the PPLI structure. Many policies are owned by trusts which can be domiciled in jurisdictions in keeping with the client’s planning needs. In terms of asset management, it is an open architecture model where the assets can be located in multiple jurisdictions with multiple asset managers. PPLI insurance costs generally average about 1 percent of the cash value of the policy, over the life of the policy.

The cost of the death benefit varies with the health and age of the insured person, and generally policies are designed with the lowest death benefit possible. Tax and enhanced privacy benefits outweigh the costs of using a PPLI structure. Asset management fees will depend on the asset manager(s) selected to manage the assets inside the policy. The policy is fully transparent to the client, as all fees and costs are disclosed.

How are cryptocurrency, EWP, and PPLI similar? All three have qualities that a wealthy homeowner would be looking for in an ideal home: architectural elements that truly “speak” to the owner; privacy; a climate that suits the owner; and a sense of security, both emotional and physical. These may seem like strange bedfellows, but what we all seek in the world, whether it is a home or a structure for our financial affairs, can be quite similar in nature.

We will illustrate this point by a few recent news items about cryptocurrencies:

Courtesy of Anne Kadet in The Wall Street Journal.

“NewYorkCoin, created in 2014 by an unknown developer, has enjoyed a surge of support in recent months. More businesses are accepting the currency and there’s a growing interest among cryptocurrency developers. There’s even a new Meetup group where enthusiasts who frequent online forums can gather in person to discuss their altcoin adventures.”

We all enjoy having a local identify and simultaneously having the sense of belonging to something larger than ourselves.  The NewYorkCoin, EWP, and PPLI have these characteristics.  The open architectural elements of EWP and PPLI can incorporate both the local and international in a structure that speaks to the client’s individual planning needs.

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?”

We are not qualified to comment on the taxation issue, but wish to use this invitation post comments to raise a salient point: the use of blockchain technology as the basis for a currency throws into question the very nature of what constitutes a currency.  Or put another way, in the future will currency continued to be issued by governments or by individuals?  The answer to this question is being played out currently on the world stage.  In the meantime, if you are concerned about the tax on cryptocurrencies, you can use a properly structured PPLI policy to shield the tax.

For some readers we may have stretched some analogies, but hopefully we have equally stretched your minds on our topics.  We appreciate your comments and are thankful for your continued trust and support.

Learn more: The EWP Stories Video Series – CRYPTO-PPLI and EWP – Episode 1

 

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

Michael Malloy-CLU-TEP

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PPLI Protects U.S. Situs Assets

PPLI Protects U.S. Situs Assets

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Estate Tax Planning for Non-U.S. Persons

Winston Churchill’s quote is apt for many who plan for wealthy international clients. Perhaps you have had this happen to you?  You receive a call from a close relative of a client who has just purchased an apartment in their own name. This relative spends considerable time in New York City. You know that the family is now exposed to U.S. estate tax, and you have to figure out how to extricate them from this issue.

Our firm focuses on the adroit and compliant concept of Expanded Worldwide Planning (EWP).  At the heart of EWP is a properly structured Private Placement Life Insurance (PPLI) policy that allows the insurance company of the assets inside the policy to become the beneficial owner of these assets.  In many cases this gives the structure additional privacy protection as well as simplicity.

Life insurance, and this includes PPLI, is a well-recognized and well-established financial planning tool. If the overall structure is properly conceived, you have a tax efficient and compliant structure that gives tax-deferred growth to the assets inside the PPLI policy.  At the death of the insured life in the policy, a tax-free death benefit transfers the assets to, in most cases, a trust that conforms to the family’s estate planning aims.

Prior to the passage of the Trump Administration’s new tax bill, many had speculated on two key possible impacts for non-U.S. persons—the elimination of the estate tax exemption disparity between non-U.S. and U.S. persons, and the elimination of the estate tax itself, which could have eliminated a long-standing reason to use offshore structures.

On December 22, 2017, Public Law 115‑97 (“Tax Cuts and Jobs Act”) was enacted amending the estate tax for U.S. persons only. Sections 2010 and 2001, both of which apply to estates of citizens or residents, did not alter taxes imposed on the estates of nonresidents who are not U.S. citizens who hold U.S. situs assets.

Under Section 2010, the basic exclusion amount for estates of resident or citizen decedents dying after December 31, 2017, and before January 1, 2026, is increased from $5 million to $10 million. But I.R.C. Sections 2101-2108 which pertain to the “Estates of Non-Residents Not Citizens,” were not amended. Accordingly, the tax imposed on the transfer of the taxable estate of decedent nonresidents who are not U.S. citizens remains subject to a minimum basic exclusion of only $60,000.

Given the continuing taxation upon death of U.S. situs assets for those private wealth clients, care is urged in planning how those assets are held. The many and varied planning possibilities inherent in EWP can be achieved through using the correct PPLI structure.  The protection of U.S. situs assets of non-U.S. persons is just one of the many uses of EWP.

If you give us a brief fact pattern of your situation, we can let you know if EWP and PPLI are the right fit for you.  We look forward to your questions and comments.

 

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

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Effective PPLI Real Estate Structures-II

Effective PPLI Real Estate Structures-2

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Part II: Outstanding Results Realized

As we discussed in Part I, foreign Investment in-bound into the United States faces many hurdles and sometimes unforeseen costs.  An insurance solution using a specific life or annuity product can greatly simplify or eliminate many of these issues and make long term investing even more appealing.

All foreign Investors are exposed to a myriad of US tax consequences, including withholding taxes (30%), capital gains, and even U.S. Estate Taxes. Life insurance, and specifically Private Placement Life Insurance (PPLI), is a well-established tax and estate planning tool that many qualified investors utilize to mitigate and manage these exposures.

PPLI combines the well documented and compliant attributes of a standard life and annuity insurance product with a flexible investment platform. The flexibility includes a broad range of asset classes and employs qualifying Separately Managed Accounts (“SMAs”) or Insurance Dedicated Funds (“IDFs”).

Most structures can remain intact with the simple addition of a compliant life or annuity policy. PPLI can accommodate most custodians, managers or funds, making the transaction as simple to set up as a trust or other less effective structures.

PPLI also provides simplified reporting and confidentiality. The policy is reported once, and not the assets held or underlying investments. The owner reports a life policy and not that they are investors or hold assets in the U.S.

PPLI provides the same tax advantages of commercial life insurance:

  • Tax free or tax deferred growth of internal cash value
  • Tax free or tax deferred payment of 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 (if applicable)

The Summary Chart below compares using PPLI with other commonly used structures.  The small additional expense of adding PPLI to a structure gives the non-U.S. person many additional benefits that cannot be achieved otherwise.

Summary Chart

  Trust with LLC Dual Corporation Individual with LLC Insurance with IDF
Capital gains tax on gain 20% 35% 20% (if over $400,000, 15% if less) 0%
Medicate tax at 3.8% rate Not necessarily No No 0%
Files tax returns in personal name Not necessarily No, but need to disclose foreign shareholders and related party transaction Always No
Excess interest expense carries forward to offset gain from sale. Yes Yes Yes, but limited No
30% withholding tax on related party interest payments No Yes, unless treaty jurisdiction lender No No
Limits on deductibility of interest expense Yes (90%) Yes (60%) Yes (80%) No
Estate tax protection No Yes No Yes

 
Distribution creates additional withholding No Yes No No

 

Your comments and suggestions are always welcome!

Please contact us to find out if this type of structure is right for you.

 

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

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PPLI OVERVIEW

PPLI: Life Insurance Defined

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#PPLI OVERVIEW

Life Insurance for International Clients

(Updated)

Private Placement Life Insurance (PPLI) has a clear advantage in structuring for international clients. In most countries life insurance is defined in their legal codes, and considered a well-accepted benefit for society as a whole. Life insurance is something every one either has or can provide needs justification.

In today’s world of increased tax transparency, after the enactment of FATCA and CRS, life insurance in the form of PPLI not only can give clients increased tax transparency, it can produce a structure that is simple and straightforward.

This is largely accomplished by the fact that in a properly designed PPLI structure the life insurance company becomes the beneficial owner of all the assets inside the policy, and only reports the total cash value of these assets—no other details.

In designing policies for international clients, we endeavor to find what are termed safe harbors. What are these safe harbors? They are sections of the tax codes of countries that clearly define a concept. We then model our structures so that the elements of the structure fit these clearly defined concepts. For those countries that use a common law approach in their tax codes, we are also able to find even safer harbors if case law rules favorably on the tax codes that we use as the framework of our structure.

So, if PPLI structures are able to solve the important issues of increased client privacy and a simplified tax transparent structure, it behooves us to establish a definition of life insurance. We will now give a brief history of how life insurance has been defined in the U.S. tax code, as it pertains to structuring for international clients.

Before the enactment of the Deficit Reduction Act of 1984, which created Code Section 7702, life insurance was only rudimentarily defined. At this time, the Code Section that gave the clearest definition of life insurance was Code Section 101(a), issued in 1957. The definition of life insurance hinged on some element of risk-shifting. The magnitude of the risk was not at issue.

A 1941 Supreme Court case, Helvering vs. LeGierse, concluded that “historically and commonly, insurance involves risk shifting and risk distribution.” This case gives us a definition of life insurance consistent with Code Section 101(a).

Fast forwarding to 1984 and Code Section 7702(a), life insurance is defined for U.S. federal tax purposes as a contract which is a life insurance contract “under the applicable law,” if it meets either the cash value accumulation test or the guideline premium test. Both of these tests are designed to insure a high level of pure death risk coverage relative to the amount of premium contribution. If it fails to meet either of these tests, a contract can be a valid life insurance contract under Code Section 7702(g).

Particularly for clients who are non-U.S. persons, we frequently employ a structure that comes under Code Section 7702(g), so that the least amount of life insurance can be used. This is the so-called Frozen Cash Value (FCV) PPLI policy. To further accomplish a tax-free death benefit to beneficiaries, we also look to Code Section 101(a) to define life insurance in this context.

As far as reporting to tax authorities is concerned, PPLI can mitigate or simplify reporting associated with pre-immigration planning and U.S. exposure, Controlled Foreign Corporation (“CFC”) holdings, FATCA, and CRS.

As always, we welcome your comments, questions, and a brief fact pattern to determine if our Expanded Worldwide Planning (EWP) concepts for PPLI structures can be employed successfully for you. We thank you for your continued trust and confidence.

 

 by Michael Malloy CLU TEP RFC, @ EWP Financial

 

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Expanded Worldwide Planning-addendum-white-paper-ewp

Addendum to White Paper on Expanded Worldwide Planning

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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
Planning.

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

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PPLI and EWP working together

Expanded Worldwide Planning (EWP) – Review

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The new paradigm for international structuring – Updated

Give Your Clients Greater Control Within a Simpler Structure Using Expanded Worldwide Planning (EWP)

Have you heard of Expanded Worldwide Planning (EWP) or International Tax Planning?

You have heard of FATCA, CRS, and BEPS – well, within these confines, why not embrace greater freedom: EWP allows you to simplify your existing structures and minimize your reporting obligations under FATCA and CRS. The total fee is approximately 1% of the client’s assets inside the structure.

At Advanced Financial Solutions Inc., we are finding that clients are requesting simpler structures that offer full transparency. This white paper introduces you to one that gives advisors multiple creative opportunities to achieve this aim.

In its core, an EWP is a properly structured Private Placement Life Insurance (PPLI) policy
in a jurisdiction appropriate to the client’s other planning needs. The other elements in the
EWP structure differ depending on the individual client situation. Advisors must factor in the client’s nationality, country of origin, country(s) of domicile, the insurance regulations of all the jurisdictions involved, the tax reporting obligations of all the entities in the structure, and the planning aims of the client. Our chart below outlines some of the possibilities for planning using EWP.

Under the segregated account legislation of the PPLI policy jurisdictions listed in our chart,
the insurance company becomes the beneficial owner of the assets inside the policy.

The reporting obligations under FATCA and CRS differ for each of the policy jurisdictions on our  chart. The goal of EWP is to give clients full compliance with all existing tax regulations while still retaining the utmost possible privacy for them.

The old offshore world is in flux and in the process of redefining itself. This creates new
possibilities for planning that did not previously exist. Whatever the nationality of your client and their very particular needs, we can supply you with compliant solutions. Each of the PPLI policy jurisdictions listed in our chart can provide vastly enhanced planning possibilities in  this open architecture environment. The trust, or other policy holder entity, can be domiciled  anywhere in the world, and the assets inside the policy can also be located anywhere in the world. Please reflect on these new possibilities. We welcome your inquiries, questions, and  comments.

Download full PDF document with graphics and notes

 

by Michael Malloy CLU TEP RFC, @ EWP Financial

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Trust Substitute by Michael Malloy

Trust Substitute by Michael Malloy

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PPLI Offers the Following Advantages

(Updated)

  • Creates viable structure for civil law jurisdictions
  • Creates new role for commercial trust company
  • Creates structure viable under specific insurance regulations

 

In most civil law jurisdictions, trusts are poorly acknowledged and trust law is not well developed 1. This can create obstacles for those domiciled in these civil law jurisdictions that have created foreign trusts. However, in certain circumstances, a PPLI structure can circumvent these problems and achieve the planning aims one would more commonly be able to fulfill with a trust in a common law jurisdiction.2

Indeed, life insurance is generally recognized in almost all jurisdictions, and a PPLI structure can actually fulfill the functions of both a trust and life insurance.

In situations where it is advantageous for the insured person under the policy to also be the owner, a commercial trust company can still act as the administrator of the assets inside the policy.

The specific insurance regulations of the domicile of both the policy owner, possibly a trust, and the insured person(s) under the policy, must be thoroughly understood for a properly executed plan using the precepts of Expanded Worldwide Planning (EWP).3 

 

Endnotes

  1. “ Wikipedia Trust in civil law jurisdictions,” https://en.wikipedia.org/wiki/Trust_law_in_civil_law_jurisdictions
  2. “Wikipedia Private placement life insurance,” https://en.wikipedia.org/wiki/Private_placement_life_insurance see section, PPLI outside the USA.
  3. supra note 2, see section , PPLI outside the USA, at References and Additional Resources, note 5.

 

 

by Michael Malloy CLU TEP RFC, @ EWP Financial

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Succession Planning

Succession Planning

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     PPLI, EWP and Succession Planning working together 

(Updated)

PPLI Offers the Following Advantages

  • Transfers assets without forced heirship rules
  • Transfers assets directly to beneficiaries
  • Transfers assets using a controlled and orderly plan

 

Many countries, primarily in civil-law jurisdictions, require forced distribution of assets at death according to strict laws and regulations.  This usually takes the form of percentage shares of assets that will be distributed to spouses, children, and other close relations of the deceased.1  A PPLI policy purchased outside the home country of the owner or policy holder is one method to mitigate these forced heirship rules.2

The PPLI policy is a contract between the owner of the policy and the insurance company to pay the beneficiary of the policy the death benefit upon the death of the insured under the contract.3 A typical beneficiary provision of a life insurance policy states:  “unless an alternate payment plan, acceptable to us, is chosen, the proceeds payable at the insured’s death will be paid in a lump sum to the primary Beneficiary. If the primary Beneficiary dies before the insured, the proceeds will be paid to the contingent Beneficiary. If no Beneficiary survives the insured, the proceeds will be paid to your estate.”  Since a typical PPLI policy is executed outside the home country of the policy owner, the forced heirship laws do not apply, as the policy will be governed by the laws where the insurance company is domiciled.4

This element of Expanded Worldwide Planning (EWP) provides a wealth holder an excellent method to enact an estate plan that conforms to his/her own wishes, and not be dictated by the forced heirship rules of his/her home country.  To be successful this needs to be well-coordinated with all the aspects of a properly structure PPLI policy, as well as all the other elements of a wealth owner’s financial and legal planning.

Endnotes

  1. “Wikipedia Forced heirship,” https://en.wikipedia.org/wiki/Forced_heirship
  2. Whelehan, “International Life Insurance: An Overview,” in International Life Insurance, edited by David D. Whelehan, JD (Chancellor Publications Limited, 2002) at 1.
  3. Christensen, Burke and Graves, Edward, McGill’s Legal Aspects of Life Insurance, (The American College Press 2008), at 1.3.
  4. supra note 2.

 

by Michael Malloy CLU TEP RFC, @ EWP Financial

Michael Malloy Contact Info