Private Placement Life Insurance and Annuities (Portfolio 870)

Description

The Bloomberg Tax Portfolio, Private Placement Life Insurance and Annuities, No. 870, discusses private placement life insurance (PPLI, also known as private placement variable life insurance) and private placement variable annuities (PPVA) and the use of these strategies as investment, income tax, estate planning, asset protection, and philanthropic tools in the high-net-worth marketplace.

This Portfolio discusses PPLI and PPVA, two core planning strategies that allow holistic advisors to address a wide variety of client needs:

 I. As investment tools, both PPLI and PPVA enable access to sophisticated investment strategies used regularly by high-net-worth investors.

 II. As an income tax planning tool, PPLI reduces income tax liability as it permits such investments to grow income tax-free.

 III. As an estate planning tool, PPLI has multiple applications that mitigate estate tax liabilities and facilitate the orderly disposition of assets at death. In contrast, PPVA is designed to supplement the client’s estate during life.

 IV. As asset protection vehicles, both PPLI and PPVA offer both financial privacy and, in some cases, significant protection from future creditors.

 V. As augmentation to philanthropic goals, both PPLI and PPVA represent powerful tools that leverage charitable giving.

Further, this Portfolio will examine all of the tax, legal, and technical considerations associated with PPLI and PPVA, including considerations regarding domestic versus international carriers as well as the associated tax reporting.

For a discussion on commercial annuities, life insurance, and long-term care insurance products, see 546 T.M. Annuities, Life Insurance, and Long-Term Care Insurance Products (U.S. Income Series).

This Portfolio may be cited as Giordani and Chesner, 870 T.M., Private Placement Life Insurance and Annuities.

Table of Contents

I. Introduction to Private Placement Life Insurance and Annuities
II. Tax, Legal, and Technical Considerations
III. Investment Considerations
IV. Planning Applications
V. U.S. Tax Reporting Requirements for PPLI Policies with Foreign Structures