introduction to private placement.ppt · an introduction to private placement insurance and annuity...
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Content intended for Agent and Broker Information Only. Not for Use with Clients or the Public.
An Introduction to Private Placement Insurance and Annuity Products
PRIVATE BANKING SOLUTIONS
Content intended for Agent and Broker Information Only. Not for Use with Clients or the Public.
Discussion Points• What is private placement life insurance?
• Why should your clients care about private placement life insurance?
• How does private placement life insurance work?
• What makes private placement life insurance different?
• What rules govern private placement life insurance?
• How is private placement life insurance distributed?
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Private Placement Life Insurance
Private placement life insurance (PPVUL) and
annuities (PPVA) utilize existing tax code
available to insurance products which, when
structured properly, allows for the tax free
growth of your client’s investment.
PRIVATE PLACEMENT LIFE INSURANCE
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PRIVATE BANKING SOLUTIONS
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Effects of current tax rates− High net worth investors are seeing
increasing federal and state tax burden
− The 2014 total effective tax rate on a high net worth individual could exceed 50% (depending on state of residency)
− Ordinary federal income tax rate increased to 39.6%, up from 35%1
− Increases in state income tax (depending on state of residency)
Erosion of Wealth
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1 http://www.irs.gov/pub/irs-drop/rp-13-15.pdf
PRIVATE BANKING SOLUTIONS
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Comparison of Income Tax Rates (Top Bracket)1
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PRIVATE PLACEMENT LIFE INSURANCE
1 http://www.irs.gov/pub/irs-pdf/f1041es.pdf, http://www.irs.gov/publications/p17/ch16.html, http://www.irs.gov/uac/Affordable-Care-Act-Tax-Provisions, https://www.ftb.ca.gov/forms/2013_california_tax_rates_and_exemptions.shtml, http://finance.yahoo.com/news/10-worst-states-taxes-2014-110000784.html, and http://www.bankrate.com/finance/taxes/state-taxes-california.aspx
PRIVATE BANKING SOLUTIONS
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• Features of PPVA and PPVUL
• What makes PPVUL different
• Potential risk factors
• Client Profile
• Case Study
PPVUL and PPVA Overview
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Traditional Retail Life Insurance Private Placement Life Insurance
Death benefit purchase Investment purchase
Maximum death benefit Minimum death benefit
Small premium deposits over multiple years Large premium deposits generally from 1 to 7 years
Minimum guarantees No investment performance guarantees
Back end fees No surrender charges
Registered investment options Non-registered, alternative investment options
Retail pricing Institutional pricing
No flexibility Flexibility
Limited transparency in pricing Full transparency in pricing
What makes PPVUL different?
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Features of PPVA & PPVUL
PPVA PPVUL
Health Underwriting No Yes
Tax deferred growth Yes Yes
Income tax free death benefit No Yes
Opportunity for favorable tax treatment on loans & withdrawals
NoYes
(if structured properly)
Segregated assets/bankruptcy remote Yes Yes
Capacity constraints No Yes
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Potential Risk Factors
• Investment Risk
• Regulatory / Audit Risk
• Carrier Risk
• Liquidity Risk
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Client Profile
• Ultra high-net-worth individuals, sophisticated investors, family offices, etc.
• Owner must qualify as an Accredited Investor (AI) and Qualified Purchaser (QP)
• Typically invested in tax inefficient investments that generate substantial ordinary income
• Looking for cash accumulation, wealth transfer, and/or charitable giving
• Typical Net Worth: $20M plus
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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• Male Age 50 Preferred Non-Tobacco• 50% Income Tax Rate (Federal + State)• Earning 7% net of investment fees• Comparison:− Taxable Investment: Single deposit of $5,000,000− PPVUL:
– $1,000,000 per year for 5 years– minimum non-MEC face amount of $18,095,720– 0% Compensation– Account Maintenance Charge: Yrs 1-10: 0.25%; 11-20: 0.20%; 21+: 0.15%
Case Study: Taxable Investment versus PPVUL
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Male, Age 50 Preferred Non-Tobacco Taxable Investment: $5,000,000 single deposit; PPVUL: $1,000,000 per year for 5 years
50% Income Tax Rate • 7% Gross Rate of Return
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Case Study: Taxable Investment versus PPVUL
$11.9MIRR: 6.4%
$8.7MIRR: 3.5%
$55.6MIRR: 6.5%
$19.8MIRR: 3.5%
PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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• Targeted towards investors who are interested in deferring income tax and
potentially reducing or eliminating income tax
• Can be further enhanced for investors who:
− Want to transfer wealth to future generations in a tax-efficient manner
− Have assets in trusts or family partnerships seeking long term tax-free asset
growth
− Wish to increase their life insurance coverage in a cost-efficient structure
PPVUL: Client Appeal
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Case Study: Taxable Investment versus PPVA
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• 50% Income Tax Rate (Federal + State)• Earning 7% net of investment fees• Comparison:− Taxable Investment: Single deposit of $5,000,000− PPVA:
– Single deposit of $5,000,000– 0% Compensation– Account Maintenance Charge: 0.35%
PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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$ M
illio
ns
Policy Cash Value Taxable Investment Value
Taxable Investment: $5,000,000 single deposit; PPVA: $5,000,000 single deposit50% Income Tax Rate • 7% Rate of Return
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Case Study: Taxable Investment versus PPVA
$13.9MIRR: 6.6%
$8.7MIRR: 3.5%
$65.1MIRR: 6.6%
$19.8MIRR: 3.5%
PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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• Investors interested in deferring income taxes
• Can be further enhanced for investors who wish to make a meaningful
charitable bequest with assets they prefer to control during their lifetime
PPVA: Client Appeal
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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• Section 7702 (life insurance)
• IRC Section 72 (annuities)
• IRC 817(h)
• Investor Control Doctrine
Applicable Federal Tax Laws
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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1980’s
• For over 30 years, corporate 500 companies, banks, and institutional investors have been utilizing insurance vehicles as a way to make the most of the tax advantages provided by the tax code through corporate owned life insurance (COLI) and bank owned life insurance (BOLI)
1990’s
• For years, high net worth clients have invested in alternative asset classes such as hedge funds and hedge fund of funds. However, investors quickly realized that strong investment performance could be offset by tax inefficiencies created by frequent trading by hedge fund managers.
2005• Changes to the regulations under Internal Revenue Code Section 817 removed the distinction
between registered and non-registered partnership interests.
Tax Code Allowing Tax-Free Growth to Investments
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Client/Purchaser
InvestmentManager
Carrier
Insurance Professional
Distribution
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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ProfileInvestment Manager & Insurance Professional
Investment Manager• Registered and non-registered funds• Tax inefficient strategy
Insurance Professional • Insurance licensed• Securities licensed
Insurance Carrier• Product provider (PPVUL and PPVA)• Onshore vs. Offshore
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Appeal of Private Placement Business
Investment Manager
• Opportunity to grow AUM• Ability to offer tax preferred investment option
Insurance Professional
• Create & generate revenue on an asset based business model• Extension of estate planning (income tax mitigation planning)
Insurance Carrier
• Strategic fit with target market (affluent and ultra affluent consumers)• Balance between traditional products and private placement products
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Conclusion• Clients are seeing an increase in federal and state income taxation
• PPVUL & PPVA can provide deferral, reduction and/or elimination of income taxation
• Only available to sophisticated investors who qualify (AI & QP)
• PPVUL & PPVA are customizable and transparent products
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PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
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Questions?
PRIVATE PLACEMENT LIFE INSURANCE
PRIVATE BANKING SOLUTIONS
Content intended for Agent and Broker Information Only. Not for Use with Clients or the Public.
Important DisclosuresZurich American Life Insurance CompanyAdministrative Office: 7045 College Boulevard, Overland Park, KS 66211-1523877-678-7534
Securities are distributed by one or more registered broker-dealers.
This presentation, and the information and materials included herein, have been prepared solely for informational purposes, and are neither an offer to sell, nor a solicitation of an offer to purchase.
Nothing herein shall constitute tax, legal, or investment advice.For agent and broker information only. Not for use with clients or the public.
Chad Nulty is a Registered Representative of BFP Securities, LLC (Member FINRA) Six CityPlace Drive, Suite 400 St. Louis, MO. 63141314-729-2210
©2014 Zurich American Life Insurance Company. A1-91968-A (06/14) 14-0099
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