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PPLI and wealthy international families.

Rarity and Value

Posted on September 14, 2018 by JC SERVICES

PPLI Will Take You Home

Private Placement Life Insurance (PPLI) is a refuge in today’s stormy sea of compliance and tax regulations. When we are distraught and confused our home becomes a safe haven. This is exactly what PPLI does for the assets of wealthy international families.

The rarity of an item tends to give it value. When this item becomes the subject of theft, it can produce more interest, and, even, greater interest if the item is later recovered. This was the case recently with the ruby slippers in the American musical, fantasy film The Wizard of Oz. In the film the ruby slippers have the magically property of taking you Home.

Let us first explore how PPLI creates a safe haven for the assets of wealthy international families. This is best done by diving into the stormy sea of compliance and tax regulations. One understands a subject by the way it is framed. In this case we are speaking about intellectually framing. Let me explain further.

When we wish to go into more depth about a subject, we must first choose a source. How this source of our new knowledge presents the topic becomes part of our new understanding of the topic. This is what I mean by intellectual framing.

Politics gives us a clear example. When we read about a political event from one news source, and, then, read about the event from another news source that has a very different political perspective the two stories can sound very different indeed.

Filippo Noseda of the Mischon de Reya law firm in London is an attorney who is active in privacy issues for wealthy international families. In Trusts & Trustees, “CRS and beneficial ownership registers—what serious newspapers and tabloids have in common,” we think his framing of the privacy vs. transparent issue is excellent. We will express his viewpoint in excerpts from the article.

“The European Data Protection Supervisor (EDPS) published a damning opinion in which he decried the unclear objectives pursued by the AMLDs and, more generally, the invasive nature and lack of proportionality of the proposed registers.”

“As if they were living on planet Europa rather than in Europe, the European Parliament, the Organisation for Economic Co-operation and Development (OECD) and politicians show complete disregard for the warnings raised by their own data protection bodies and instead appear hell-bent on introducing a system of total transparency.”

“Data protection has moved to the forefront of people’s minds, prompting the EU to overhaul the existing data protection rules and has also led to a number of ground-breaking decisions by the European Court of Justice which confirms that the pendulum has started to swing back towards greater protection of privacy and data protection.”

“It is somewhat curious that serious newspapers who have been covering both the private banking scandals and the erosion of privacy seem unable to make the connection between data protection on the one hand, and the CRS and beneficial ownership registers on the other.”

In structuring assets for wealthy international families, the insurance company of the PPLI policy becomes the beneficial owner of the policy’s assets. This structure gives compliance simplification, as what is reported to tax authorities is the total of the assets inside the PPLI, and not the individual assets inside the policy. At the death of the insured life in the PPLI policy, the assets pass as a tax-free death benefit to the beneficiaries.

Let us return to The Wizard of Oz and the ruby slippers. These magic, ruby, slippers had the property to take you Home once you clicked your heals together three times. The slippers were stolen thirteen years ago from the Judy Garland Museum in Grand Rapids, Minnesota. They were recently recovered by the FBI and returned to the Museum. Of course, this publicity gave the slippers added value, and increased their rarity as something unique.

With PPLI you don’t need the ruby slippers to take you Home. You gain protection from the stormy seas of tax compliance by having your assets inside a PPLI policy, so you are Home from the beginning. You also won’t have your assets taxed, since they are inside a tax-free environment.

We invite your participation in our quest to take you Home to a truly unique structuring tool that has rarity and value. Please write your thoughts and questions at the bottom of the page. If you want to communicate privately with me don’t hesitate to drop me a line: michael@michaelmalloy.solutions

Thank you.

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

#michaelmalloy #michaelmalloysolutions #advancedfinancialsolutions #ppli

The Beauty of The Integrated Circuit

Posted on August 31, 2018 by JC SERVICES

PPLI: The Computer Chip of Wealth

Private Placement Life Insurance (PPLI) is a type of integrated circuit, read computer chip, in planning for wealthy international families. Both of these remarkable structures remain in the background, and what is visible is the amazing things that they accomplish.

If you have ever opened up the inside of a laptop computer, you see a bewildering array of small devices connected by tiny wires–the world of integrated circuitry This is similar to the PPLI flow charts that are firm produces to model the worldwide investments, hard assets, real estate holdings, and companies of the wealthy international families that we serve

Courtesy of Sparkfun we have this definition,

“Integrated circuits (ICs) are a keystone of modern electronics. They are the heart and brains of most circuits. … An Integrated Circuit is a collection of electronic components – resistors, transistors, capacitors, etc. – all stuffed into a tiny chip, and connected together to achieve a common goal.”

Let us look at a typical flow chart for a PPLI policy. Now isn’t our analogy making more sense? Just imagine the boxes to be computer chips.

Andy Kessler in his recent Wall Street Journal article, “The Chip That Changed the World,” describes how essential integrated circuits are in our lives today.

“Integrated circuits are the greatest invention since fire—or maybe indoor plumbing. The world would be unrecognizable without them. They have bent the curve of history, influencing the economy, government and general human flourishing. The productivity unleashed from silicon computing power disrupted or destroyed everything in its path: retail, music, finance, advertising, travel, manufacturing, health care, energy.”

Noted tax attorneys David Neufeld and Grant Markuson give us excerpts from, “Keeping It All Using Private Placement Life Insurance To Achieve Tax Free Investment Returns.” We thank them for their insightful remarks on PPLI.

“Few financial choices are more critical than protecting an investment portfolio from taxes. One of the most powerful but little known and under-used tools to achieve this is a private placement life insurance (PPLI) policy. By placing an investment portfolio within this life insurance vehicle, investors can convert an otherwise taxable portfolio into one in which no income or capital gains taxes accrue, ever.

PPLI can be especially relevant to angel investors who have a wide range of investments — including private equity — that have the potential to produce sizable capital gains. As a service to our readers, Angel Investor asked David Neufeld and Grant Markuson, tax attorneys at Markuson & Neufeld, to introduce our readers to this important investment vehicle.

Using PPLI as a Component of an Estate and Income Tax Plan Standing alone, PPLI offers powerful income tax planning opportunities. The gains and income earned on the investments forming the underlying funding of the policy do not incur federal or state income tax. Equally important, this tax saving is permanent, not simply a deferral to some future date. Once the insured dies, the insurance proceeds — reflecting the then-current value of the investments plus the insurance component — should be received by the beneficiaries income tax free.

The PPLI does not only benefit the beneficiaries upon the death of the insured; it also can benefit the policy owner during his or her life, by permitting loans of the cash value without triggering any income tax on the realized gain. Interest payments simply go back into the policy value.”

In today’s world attempting to hide assets from tax authorities only draws more attention to them. Why not use a “background structure” like PPLI to not only shield assets from tax but also gain enhanced privacy. Please let us know how we can assist you in these planning aims.

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

#michaelmalloy #michaelmalloysolutions #advancedfinancialsolutions #ppli

Overcoming Obstacles Gracefully

Posted on August 24, 2018 by JC SERVICES

Let PPLI Show the Way

Private Placement Life Insurance (PPLI) is a vehicle to overcome obstacles for structuring assets for wealthy international families. This is greatly aided by the concept of Expanded Worldwide Planning (EWP). Sometimes inspiration is necessary to overcome obstacles. To find this inspiration look no further than the remarkable life of Helen Keller. We will learn more about her amazing life later on, but first, let us focus on EWP.

We find the definition of EWP in the Wikipedia page International tax planning. Here is the opening paragraph:

International tax planning also known as international tax structures or expanded worldwide planning (EWP), is an element of international taxation created to implement directives from several tax authorities following the 2008 worldwide recession.

Further explanation is given in the Principles section:

EWP allows a tax paying entity to simplify its existing structures and minimize reporting obligations under the Foreign Account Tax Compliance Act (FATCA) and CRS. At the heart of EWP is a properly constructed Private placement life insurance (PPLI) policy that allows taxpayers to use the regulatory framework of life insurance to structure assets along the client’s planning needs.

These international assets can also comply with tax authorities worldwide. EWP also brings asset protection and privacy benefits that are set forward in the six principles of EWP below. The other elements in the EWP structure may include the client’s citizenship, country of origin, actual residence, insurance regulations of all concerned jurisdictions, tax report requirements, and client’s objectives.

Planning with trust and foundations frequently offer only limited tax planning opportunities, whereas EWP provides a tax shield. Adding a PPLI policy held by the correct entity in the proper jurisdiction creates a notable planning opportunity.

The Six Principles of EWP

To address the obstacles in structuring assets for wealthy international families, these six principles are incorporated in the solution to produce the best possible planning outcome for the family.

Privacy

Asset Protection

Succession Planning

Tax Shield

Compliance Simplifier

Trust Substitute

The Life of Helen Keller

We return to Wikipedia for this summary of the remarkable life of Helen Keller:

Helen Adams Keller (June 27, 1880 – June 1, 1968) was an American author, political activist, and lecturer. She was the first deaf-blind person to earn a bachelor of arts degree. The dramatic depictions of the play and film The Miracle Worker made widely known the story of how Keller’s teacher, Anne Sullivan, broke through the isolation imposed by a near complete lack of language, allowing the girl to blossom as she learned to communicate. Her birthplace in West Tuscumbia, Alabama, is now a museum and sponsors an annual “Helen Keller Day”. Her birthday on June 27 is commemorated as Helen Keller Day in the U.S. state of Pennsylvania and was authorized at the federal level by presidential proclamation by President Jimmy Carter in 1980, the 100th anniversary of her birth.

Thankfully in our EWP and PPLI structuring we do not face the tremendous challenges faced and overcome so gracefully by Helen Keller. She can serve as a model for all of us for what is possible in the face of extreme difficulty. As always, we welcome your comments and questions.

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

How Is Change Implemented with PPLI?

Posted on August 3, 2018 by JC SERVICES

Change Comes Slowly to PPLI

Private Placement Life Insurance (PPLI) gives wealthy international families a conservative structure to achieve enhanced privacy and a tax free environment for their assets. At first glance, it would not seem that PPLI would share something in common with Ralph Lauren, the well-known fashion designer, but read on, and you will see how they are connected.

PPLI structuring is basically using available laws and regulations to the best possible advantage for each unique family situation. Why not take a “straight and narrow” route and avoid issues with the tax authorities of all the countries involved in the structure?

Life insurance is well established in the laws and regulations of most countries in the world. It is considered a benefit to society:

“Life insurers are vital to an efficiently functioning modern economy and society and are a key contributor to long-term economic growth and improved living standards,” states a 2016 report by The Brattle Group, “The Social and Economic Contributions of the Life Insurance Industry.”

Because life insurance permeates the social fabric at all economic levels, the laws and regulations on life insurance tend to be more stable and less subject to political change. Later on we will give you an example of how a tax law change in the U.S. is playing out in a complex manner that will take many years to fully resolve.

What are a few key elements that show us why it is vital to use life insurance in structuring for wealthy international families? Here are two significant ones:

Simplified Reporting

A compliant PPLI policy is an asset that can hold various investments, including multiple underlying traded or non-traded companies as well as private equity. The insurance company is legally seen as the owner of these investments, hence this simplifies the reporting requirements under most reporting regimes. CRS reporting is also simplified and limited, based on correct structuring at the inception of the process.

Asset Protection

PPLI can offer privacy and, in some cases, significant protection from creditors. Assets held in a PPLI policy are held in a Separate Account and are protected from the assets of all other policyholders and the general account of the insurance Company.

Here is our example of how a recent tax law change is playing out in the U.S.

New Hampshire Fights Supreme Court

Sales-Tax Ruling

Retailers in five states without a sales tax face new burdens

New Hampshire is one of five states without a broad-based statewide sales tax, a status that had insulated retailers from a task familiar to businesses elsewhere. That cushion lasted until the U.S. Supreme Court’s June decision in South Dakota v. Wayfair, which lets states require retailers to collect sales taxes even if those businesses lack a physical presence in the state.

States with sales taxes are still figuring out how they’ll approach out-of-state retailers. New Hampshire, with a special legislative session scheduled for Wednesday, isn’t waiting to respond. Its reaction to the court’s decision will spur the next round of skirmishes over cross-border sales-tax collection.

States with sales taxes are working on their regulations to get out-of-state sellers registered in their systems and collecting the tax. In some cases, they need to wait for their legislative sessions for new or revised laws.

Does all this sound familiar? Change the actors and subject matter in the play and you have the worldwide reactions to implementing FATCA, CRS, Registers of Beneficial Ownership and other mandates from governments and regulatory bodies around the world.

Although far from timeless, our firm’s PPLI structures that use life insurance as its core element have withstood many years of changes in transparency, tax legislation, and calls from government officials to end “aggressive tax planning.” Planning with life insurance could be seen as the eye of the hurricane–an area of calm in the midst of constant change. We achieve outstanding results without being aggressive.

We thank Ralph Lauren for his quote, and enjoy the challenge of securing exceptional results that have weathered many storms. As always, we welcome your comments and questions.

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

#michaelmalloy #michaelmalloysolutions #advancedfinancialsolutions #ppli

The 80/20 Rule

Posted on July 27, 2018 by JC SERVICES

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

What Is Time?

Posted on July 19, 2018 by JC SERVICES

PPLI Stops Time

This week we will learn how a sophisticated structuring technique for wealthy international families, Private Placement Life Insurance (PPLI), has the ability to stop time. Yes, this may seem at first hearing outrageous, but from a tax and privacy perspective, this will be the conclusion of our article.

If PPLI has this ability, we must first define time. A tall order, you say. Let us look at a few quotes from William Shakespeare to get our bearings.

“Make use of time, let not advantage slip.”

“Let every man be master of his time.”

“I wasted time, and now doth time waste me.”

From these three quotes, we read that one element of time is scarcity: you only have so much of it. And through your use of time, it is possible to place your affairs in more favorable circumstances.

What happens when assets are placed in a properly structured PPLI policy? These assets enter a privacy enhanced and tax-free environment. If this structure is properly maintained, from the time the policy is issued until the death of the last person insured under the PPLI policy, the assets are not subject to tax and receive enhanced privacy. As far as tax laws are concerned TIME HAS STOPPED.

PPLI and Tax Law

Let us leave the realm of poetry and re-enter the domain of tax concepts. One element of tax law that is germane to time is the concept of constructive receipt.

According to Investopedia, “Constructive receipt is a tax term mandating that an individual or business must pay taxes on income despite the fact that it has not been physically received. An individual is considered to be in constructive receipt of income when they have the ability to control or utilize the funds, even if they do not have direct possession of them, or if it is guaranteed they will have the ability to draw upon the funds in the future. A business is said to be in constructive receipt if the business has the ability to use the money without restriction or if it has been deposited into the business’ account. Constructive receipt of income prevents taxpayers from deferring tax on income or compensation they have not yet utilized or spent.”

The concept of constructive receipt is no longer applicable to a properly structured PPLI policy, because the assets have been reconstituted inside an insurance policy. The insurance company is now the beneficial owner of these assets for reporting purposes. When a family wishes to receive funds from the policy, they are distributions from the PPLI policy, and only charged a small fee, most usually around 25 basis points.

Again, the laws usually applicable to the assets inside the policy no longer apply. TIME HAS STOPPED.

Our firm gladly welcomes your structuring challenges, questions, and comments. We wish to participate in your quest to, as Shakespeare says, “Make use of time, let not advantage slip.”

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

What Is Money?

Posted on July 12, 2018 by JC SERVICES

Fungibility Is Key to PPLI

At the center of a Private Placement Life Insurance (PPLI) structure is fungibility. For PPLI this means in essence taking assets in a taxable environment into one that is tax-free. According to the Merriam-Webster dictionary, fungibility derives from the Latin verb fungi meaning “to perform (no relation to the noun “fungus” or the plural “fungi.”)

If something is fungible it is mutually exchangeable like an ounce of gold, or in other circumstances, as we will read further on in our article, the U.S. dollar held in the form of $100 bills.

This mutual exchange for a taxable environment for one that is tax-free is accomplished in PPLI by using life insurance. Perhaps a fungible transaction is not quite the right analogy.

Life insurance in the structure functions more like a membrane, where once the assets are properly structured inside the PPLI policy, the assets become recharacterized into a solution that has both outstanding tax benefits as well as enhanced privacy. Clients also can permeate this membrane for tax-free distributions on the income from the assets.

Worldwide life insurance has a tax-favored status, and this exchange from taxable to non-taxable can be accomplished with the creation of a PPLI structure that takes into account these key elements in a wealthy family’s situation:

Nationality of the family members;
Country of residence(s);
Location and type of assets;
Laws pertaining to trusts, life insurance, and other entities to be used;
Aims and goals of planning.

Once these elements are researched and analyzed, a tailor-made structure can be created for the family. Wealthy international families are drawn to PPLI structures, in part, because of the legitimate enhanced privacy that can be accomplish inside this structure.

Governments and their tax authorities are in place, in the highest form, to secure the public good through the collection of taxes. Their citizens also have rights to privacy and, within the realm of law, to protect their private property from harm. Therefore, there is a built-in tension between these two aims.

Another built-in tension can occur in the financial world. What happens when a country’s institutions don’t support a traditional banking system? One occurrence is that new systems are created to support the unique circumstances. Let us take the extreme example of Somaliland.

For this example teaches us one of the underlying properties of what we call money: a means to facilitate a transaction. We are thankful to Matina Stevis-Gridneff in a recent Wall Street Journal article for these excerpts.

“An Isolated Country Runs on Mobile Money”

“HARGEISA, Somaliland—Hyperinflation and economic isolation have pushed this poor, breakaway republic closer to a virtual milestone than most other countries in the world: a cashless economy.

The continent, home to many of the world’s frontier economies, has come closest to skipping, or “leapfrogging” as it’s often called, traditional brick-and-mortar banks and going straight to heavily using phones as wallets.

And nowhere are the benefits of mobile money more apparent than in Somaliland, where the extreme economic and financial conditions have allowed Zaad, a service from the main local telecom, Telesom, to catalyze commerce in one of the most isolated parts of the world.

Once a week, Abdulahi Abdirahman hauls two bulky, heavy sacks of shillings from his gas station across Hargeisa to the money-exchange area downtown and, several hours later, returns with just a few dollar notes in his back pocket and his Zaad wallet loaded up.

Clients pay Mr. Abdirahman in Somaliland shillings. He needs to pay suppliers in dollars. Using Zaad, he gets half the payments in mobile money, meaning the cumbersome ritual has become more manageable in these times of high inflation.”

Money in Action Using PPLI

Now, again courtesy of The Wall Street Journal, by Joe Craven McGinty, we find another example of how money works in the real world.

“Cash Flow or Cash Stash? How Money Moves Around”

A record level of U.S. cash is circulating, but Americans aren’t spending the bulk of it.

So, where’s the money?

Up to two-thirds—or as much as $1.07 trillion—is held abroad. About $80 billion is held domestically by depository institutions. And the rest—as little as $453 billion—is in the hands of domestic businesses and individuals.

Last year, according to figures published by the Fed, $1.6 trillion was in circulation, including $1.3 trillion in $100 bills, or 80% of the total. In 1997, $458 billion circulated, including $291 billion in $100s, or 64% of the total.

The circulating currency held abroad could range from one-half to two-thirds of the total, the Fed estimates, or a range of $800 billion to $1.07 trillion.

Wealthy families worldwide have the option of creating their own unique structures using PPLI. These structures can become, in effect, private banks. By uniting PPLI with family assets and a bespoke banking relationship, much is achieved that cannot be accomplish in any other way. Please let us know how we can assist you in this endeavor. We welcome your questions and comments.

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

PPLI: Uses Non-Disruption to Achieve Disruption

Your Pot of Gold Under the Rainbow

Posted on June 29, 2018 by JC SERVICES

PPLI: Uses Non-Disruption to Achieve Disruption

Private Placement Life Insurance (PPLI Category in our blog) shares a key element with so-called disruptive companies–innovative efficiency. This is expressed in the likes of companies such as Uber and Airbnb. Uber can be thought of as the world’s largest taxi service, but they own no vehicles. Airbnb has been called the world’s largest hotel, yet they do not own hotel buildings.

They both offer a new approach to common needs: transportation and lodging services. PPLI offers just such a structure for wealthy international families–an efficient tax-free environment for their assets.

One outstanding difference between PPLI and disruptive companies is that PPLI uses what might be called a retro structure, life insurance. We can then also call it a non-disruptive structure that offers benefits that far exceed those of many planning techniques for wealthy international families. What are these outstanding benefits:

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 PPLI structure provides excellent asset protection.
The PPLI structure is low cost with fees averaging 1% of assets.
The PPLI 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.

A recent example from the financial world, which has similarities Uber and Airbnb, caught our attention this week, courtesy of The Wall Street Journal by Maureen Farrell and Liz Hoffman:

“Upstarts Crash Wall Street’s $7 Billion Capital-Markets Party”

Ex-bankers from Goldman Sachs, JPMorgan hang out shingles to advise companies on securities offerings

When Twitter Inc. TWTR -1.07% was looking to raise $1 billion from investors earlier this month, it put out the usual calls to Wall Street banks.

The social-media company also called Vijay Culas, who works out of rented office space on a busy stretch of highway in San Mateo, Calif.

A former Goldman Sachs GS +1.06% Group Inc. banker who hung out a shingle in 2014, Mr. Culas helped Twitter negotiate with its banks and ultimately sell a type of hybrid bond for a 1% fee, one of the cheapest offerings in recent memory.

Mr. Culas is among a handful of upstart advisers who are challenging investment banks on turf once thought impenetrable: the $7 billion-a-year business of handling complex stock-related transactions.

Our non-disruptive approach to planning for wealthy international families is expressed in our embrace of Expanded Worldwide Planning (EWP). In the Wikipedia page International tax planning, you will find both the history of EWP and its key elements.

We welcome your inquiries. Our worldwide staff is here to serve your planning needs.

Please contact us today to discuss your own unique situation.

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

How PPLI Negotiates for You

Posted on June 15, 2018 by JC SERVICES

World Leaders Teach EWP

Negotiating is at the heart of Expanded Worldwide Planning (EWP), and Private Placement Life Insurance (PPLI). What can we learn from the much publicized negotiation between Donald Trump and Kim Jong Un? One thing is obvious about this meeting. We don’t really know much. The most substantive talks were held in private between the two leaders. As the saying goes, “After all is said and done, more is said than done.”

So what we read in the press about this negotiation is mostly speculation and conjecture, and another part is supplied by our own attitudes towards these world leaders and their countries. This is precisely what is avoided in EWP. By using a properly structured PPLI policy, we are able to build a plan on a strong foundation of knowledge.

A good part of this solid foundation is insurance regulations. These regulations tend to be simpler and more straightforward than the tax codes of the world’s countries, and supply many key benefits that are not allowed under tax codes.

One definition of negotiating from the Wiktionary is “To succeed in coping with, or getting over something.” This is why we can say PPLI NEGOTIATES FOR YOU. It allows you to succeed using the key elements of EWP: privacy, asset protection, succession planning, tax shield, compliance simplifier, and trust substitute.

How this ability to succeed in planning for wealth international families plays out in detail depends on the particulars involved: where the family reside; the tax codes of the countries where the various family members reside; the nationalities of these family members; the assets involved; and most importantly, the tax and estate planning aims of the family. All these elements are part of a successful EWP engagement, and what our firm enjoys most–giving families the most cost efficient and comprehensive plan possible.

History of PPLI

In the various press stories on the Trump and Kim Jong Un negotiation are historical perspectives going back to Kim’s father and grandfather. This made us realize that we have never given you a history of PPLI. Here is a short one courtesy of Trusts & Estates by Grant R. Markuson.

“PPLI really began as a way of customizing specific types of insurance products as part of corporate benefit planning for senior executives. Although the rank and file employees may have been happy with the benefits of more typical insurance offerings, senior executives often desired greater investment options, lower fees, and greater overall customization. This, in conjunction with the growing use of variable contracts, led to the birth of individualized PPLI products. The Internal Revenue Service (Service) initially ruled on these types of customized variable products in a series of Revenue Rulings from 1977-1982.

In the early 1990s, PPLI products for wealthy individuals surfaced again out of the Channel Islands. Soon after that, Cayman Island and Bermuda based products started to surface. As the hedge fund industry started to pick up steam during this period, many of the products were being specifically developed for these investments. In the mid 1990s, many of the major U.S. and European carriers entered the international PPLI market, which brought this type of planning back into the mainstream.”

To bring our brief history up to the present, we find a robust appetite for PPLI and EWP at present with the fast paced growth of wealthy international families throughout the world. Using PPLI and EWP at the service of these families can achieve bespoke solutions not possible with other methods of international tax planning.

We welcome the opportunity to negotiate on your behalf and reach a successful result for all concerned. Thank you for your continued trust and support. Please give us your thoughts.

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

PPLI Hits the Mainstream with Bloomberg

Posted on June 8, 2018 by JC SERVICES

EWP: A Giant Structuring Tool

Since we work with wealthy international families, we are expert in using Private Placement Life Insurance (PPLI) as a structuring tool. Our approach is called Expanded Worldwide Planning (EWP). A few weeks ago Bloomberg ran an article on PPLI, “How to invest in Hedge Funds and Pay No Taxes.” We offer quotes and a video about the article below.

First some basics on EWP, and how a properly structured policy can excellently serve the needs of wealthy international families.

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 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 death benefit.

More on Product vs. Structure

The Bloomberg article mentioned above speaks about PPLI as a product, which of course it is, but most importantly it is an EWP structuring tool. One quote from the article is of note:

“When I would talk about it years ago, people looked at you funny,” said Edward Gordon, founder of Preservation Capital Partners. Lawyers for the wealthy hadn’t heard of PPLIs and often dissuaded their clients from trying a product that “sounded too good to be true,” he said. Now, “it’s reaching somewhat of a tipping point.”

Unfortunately, the ignorance of PPLI’s planning possibilities even goes beyond lack of knowledge. Many asset managers naively sell against insurance structuring, and do not realize that the unique tax advantages of PPLI will give the assets they manage a significant boost in performance. This is especially true for long-term investments, and those intended for future generations.

Here are some other key quotes from the Bloomberg article by Heather Perlberg and Ben Steverman.

“This is a sexy product that people get excited about owning and tell their friends about,” said Aaron Hodari, a managing director at the advisory firm Schechter Wealth. “It’s an alternative investment that allows you to invest in hedge funds and defer or eliminate taxes.”

“Athletes, celebrities, and family offices are embracing private placement life insurance, or PPLI, as a way to preserve wealth for their heirs. It’s a strategy that’s perfectly legal and has existed for decades. While insurance funds are typically a way to protect assets from lawsuits, the main appeal of PPLIs is that they can help investors avoid taxes on capital gains, ordinary income and high-net-worth estates.”

Bloomberg’s Peggy Collins now offers us a short video about the Bloomberg article:

We invite you to explore with us the structuring possibilities of PPLI and EWP. As always, your comments and questions are indeed welcomed and appreciated.

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