Our Blog Posts and Presentations in PDF by Michael Malloy, CLU, TEP – Page 2
How do we achieve understanding?
Our next five articles will comprise an in-depth look at the five main components of our PPLI Concept Map: Professor PPLI to the Rescue.
“I understand it is raining on my assets.”
This Private Placement Life Insurance (PPLI) client is frustrated and resorts to a seemingly obtuse statement to his advisor. Let us examine his statement more closely. If something valuable would be left out in the rain, it might be spoiled. Indeed, even a PPLI asset can take a turn for the worse.
Professor PPLI has arrived to educate our advisor on what PPLI can accomplish for this frustrated client. We continue our analogy of rain, and cast Professor PPLI in the role of the rainmaker, which the Cambridge English Dictionary defines as “someone who makes a lot of money for a company or who helps someone or something to succeed.” This is an apt description of Professor PPLI. As you will find out, Professor PPLI has a studious approach to the tax savings and tax compliance benefits of PPLI, (Private Placement Life Insurance).
4. Inside and Outside PPLI – Academics Teach Us a Lesson
The magic comes once assets are inside the PPLI policy. This magic is partly due to what occurs outside the PPLI policy. We likened this in Part 2 and Part 3 to the “wind and rain.” Let us define this “wind and rain” in terms of tax policy, and compare it to the benefits of using a properly structured PPLI policy.
In our earlier articles we entertained several views on the word rain, and explored various ways that the English language used the word rain in colorful ways to describe its effect on a client’s assets. Professor PPLI has a rye sense of humor! You will receive more in this vein further in our article from Lewis Carroll’s Alice in Wonderland. Professor PPLI meets his match in the person of the Caterpillar.
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.
When the elements of a transaction are balanced it produces Harmonious Efficiency. This is exactly what is achieved for the assets of wealthy international families in a properly constructed Private Placement Life Insurance Policy (PPLI). PPLI is a product that dates back to the 1980s, so you are not employing something that was invented yesterday.
8. PPLI AND JURISDICTIONAL ISSUES – Whose Jurisdiction Is This? – Private Placement Life Insurance Defines and Simplifies
A proper understanding of jurisdictional issues is key to a successful Private Placement Life Insurance (PPLI) structure. One cannot simply take the assets of wealthy international families and move them offshore and expect a good result. The tax residence of the family is paramount, as well as the tax residence of the beneficiaries. A PPLI structure that is successful in one country, might not work in another. These factors must be thoroughly researched for the wealthy international family to have a successful PPLI structure. Since these PPLI structures tend to be long-term the necessity for this thorough research is even more compelling.
Private Placement Life Insurance (PPLI) allows you to achieve levels of legitimate privacy not possible with solely planning with trusts. The PPLI policy works in harmony with a trust to create an environment of enhanced privacy. So what war are we talking about? This war is being played out worldwide almost daily between governments and individuals on what constitutes privacy.
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.
“Simplicity is the ultimate sophistication.”
The transformation from simplicity to sophistication can be accomplished through the rule of law. In our PPLI work for wealthy international families, we must frequently turn complex and sometimes contradictory tax laws into a simple, understandable, and workable structure.
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.”)
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.
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.
Part 1: Our next five articles will comprise an in-depth look at the five main components of our PPLI Concept Map: Professor PPLI meets Leonardo da Vinci.
Part 2: Although the basic framework of Private Placement Life Insurance (PPLI) policies is similar, each client situation is unique, and, therefore, calls for a new area of study. We use our past experience to bring the best possible outcome to a new set of circumstances.
-PPLI’s Beautiful Architecture
Part 3: What does beauty have to do with Private Placement Life Insurance (PPLI)? This is what we will explore in our article today. The tax compliant, conservative PPLI structuring techniques employed by Advanced Financial Solutions, Inc. have their own language of beauty which Leonardo da Vinci exemplified visually in his painting techniques.
Part 4: Those of us who create Private Placement Life Insurance (PPLI) asset structures for wealthy clients can find beauty in a well-designed structure that is implemented successfully to achieve the aims of privacy, asset protection, and tax reduction. It is a type of architecture or engineering that uses laws, concepts, and ideas and blends them with the family dynamic and country specific challenges of each highly individual case.
Part 5: In this series, our earlier articles spoke about the advantages of using PPLI companies domiciled in locations such as Barbados, Bermuda, and other jurisdictions with insurance codes that enhance the possibilities of structuring assets with PPLI. For those with a connection to the U.S., we stressed the importance of using PPLI companies that have made a 953(d) election. We now will add a powerful third element, a PPLI policy that is termed Frozen Cash Value. This is a policy that fails to meet the IRS’s various cash value tests for code section 7702, and qualifies as life insurance under 7702(g).
Part 1: 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.