Private Placement Life Insurance (PPLI) Established in US in ‘90’s Designed for High and Ultra Net Worth Clients Provides Compliant Tax Free Compounded Earnings inside Life Insurance Policy (tax inefficient assets) Investments Managed by IM of Client’s Choice (wide range of investments) Asset Protection Open Architecture, Full Disclosure No loads, efficient pricing Domestic or International Sticky Money FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
Introduction to Insurance and PPLI TYPE OF INSURANCE NEED TEMPORARY PERMANENT TERM INSURANCE UNIVERSAL LIFE VARIABLE WHOLE LIFE PRIVATE PLACEMENT LIFE Temporary Protection No Cash Value Non-Renewable at Older Ages Availability & Capacity Constraints Permanent Protection Non-Transparent Pricing Premium & Death Benefit Flexibility Cash Value (Tax Deferral) Potential Rate of Return Permanent Protection Insurer Manages Assets 3-4% Guaranteed ROR Capacity Premium & Death Benefit Flexibility Market Generated Returns Permanent Protection No Guaranteed ROR Moderately Competitive Pricing Availability & Capacity Constraints Premium & Death Benefit Flexibility Permanent Protection High Investment Flexibility No Guaranteed ROR Highly Competitive Pricing (transparent) Significant Capacity Premium & Death Benefit Flexibility FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
Typical Domestic versus International Pricing *BOY, Pricing may reflect expenses in first year or amortized in attempt to enhance early year CSV’s FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
FOR INFORMATION ONLY AND NOT FOR PUBLIC USE U.S. vs. Canadian PPLI Major Differences: Diversification rules IRC 817(h) Investor Control Rev. Rul. 2003-91 Insurance Dedicated Funds (IDF) Definition of Life Insurance 7702(a) vs MTAR None applicable in Canada FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
Why Joint/Dual Compliant IRS: Long Reach of Uncle Sam Definition of Life Insurance 7702(a) vs MTAR, Exemption Test Section 306 FATCA FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
Fact Pattern Male 55, non-smoker, standard risk Premium $520,000 for 4 years Interest rate 6% US citizen living in Canada
FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
FOR INFORMATION ONLY AND NOT FOR PUBLIC USE
FOR INFORMATION ONLY AND NOT FOR PUBLIC USE Summary First of its kind Compliant on both sides No investor control or diversification requirements No DAC tax No State or Provincial premium taxes FOR INFORMATION ONLY AND NOT FOR PUBLIC USE