IRS Tax Audit Strategy

Private placement life insurance is a pre-emptive IRSfunds, private equity, derivatives, and real estate
audit tax strategy that transforms taxable ordinaryinvestment trusts (there are functionally no restrictions
income and capital gains into tax-free income (with noon the types of investments that can be held and
income tax reporting required under current U.S. Law).managed inside the policy).
Please reference IRS Private Letter Ruling 200244001Other benefits include the following:
(May 2, 2002).1. Short-term capital gains (41% Federal/California
For U.S. Persons with investment income, privateincome tax): exempt from income tax.
placement life insurance provides for compliant,2. Bond interest (taxed at 41% ordinary income rates
tax-free compounded earnings.Federal/California): exempt from income tax.
A private placement insurance policy is variable in3. Policies in certain jurisdictions (e.g., Cayman Islands):
nature, which allows the insurance company to investexempt from creditor attachment.
the majority of the premium(s) in a legally separate,4. IRS audit risks are minimized since assets held under
segregated account to be managed by either ana qualifying life insurance policy are neither subject to
investment manager of the client's choosing or theincome tax, nor is there any required income tax
insurance company itself. There are no guaranteesreporting (under IRC §72(e)(5)). In addition to the
when it comes to the investment performance (as itsubstantive tax and reporting benefits, for audit
varies, so does the death benefit but with a fixedpurposes there would be no presumed IRS tax
minimum).avoidance, due to the fact that life insurance has been
The income tax benefits are:granted an "angel exception" (i.e., is an IRS approved
1. Assets inside a life insurance policy grow andtransaction) (IRS Revenue Procedure 2004-65,
compound income tax free.2004-66, 2004-67, 2004-68).
2. Death benefit paid income tax free.5. Policy lifetime withdrawals may be tax-free and not
Domestically in the U.S., investors have traditionallysubject to tax reporting (as either a return of premium
used the tax benefits of variable life insurance policiesbasis or a loan). The Modified Endowment Contract
to invest in mutual funds. In contrast, international("MEC") rules may or may not apply depending on
private placement life insurance policies allow users topolicy design.
invest in a wider range of investments including hedge