Maximizing Tax Efficiency with EWP and PPLI

 Unlocking International Wealth Planning

EWP and PPLI working together

In today’s era of tax transparency, we delve into the world of international tax planning and present a solution that can help families reduce their tax burdens while ensuring compliance with tax authorities. Welcome to the realm of Expanded Worldwide Planning (EWP) and the power of Private Placement Life Insurance (PPLI).

Gone are the days when tax codes mirrored ancient civilizations like Hatshepsut’s temple in Egypt. In our modern global economy, governments face the challenge of taxing individuals and businesses that extend beyond their borders. At EWP Financial, we are staunch advocates of EWP, which offers families a simplified framework through carefully structured PPLI policies.

Our approach encompasses innovative strategies, and one such element lies in the realm of in-kind premium payments. By partnering with insurance companies located in jurisdictions that accept non-cash contributions, we empower families to use their assets and businesses as premium payments, rather than relying solely on cash. This flexibility opens doors to significant tax savings without compromising compliance.

PPLI is a customized solution designed exclusively for families seeking tax advantages. Under this globally recognized and tax-favored umbrella, various asset classes can flourish. While PPLI is popular in the United States for tax optimization in securities, such as high-tax hedge funds, our expertise extends beyond borders to cater to the diverse international holdings of families. We construct adaptable structures that accommodate multiple asset classes, including companies, valuables, and collectibles, going beyond the realm of traditional securities.

Here are some fascinating facts to ponder, gleaned from sources like Wikipedia’s articles on “Tax” and “Taxation in the United States”:

– Ancient Egypt, during the First Dynasty around 3000–2800 BC, witnessed the first known system of taxation. The Pharaoh would tour the kingdom every two years, collecting tithes and maintaining records on limestone flakes and papyrus.

– Pre-French Revolution, effective tax rates in Britain exceeded those in France, mainly targeting international trade. In France, taxes were lower but weighed heavily on landowners, individuals, and internal trade, resulting in heightened resentment.

– Historically, taxes on the poor supported the nobility, whereas modern social-security systems aim to support the poor, disabled, or retired by levying taxes on those still actively working.

– The first federal income tax in the United States was introduced as part of the Revenue Act of 1861, although it lapsed after the American Civil War. In 1913, the Sixteenth Amendment to the United States Constitution allowed the federal government to levy income taxes on both property and labor.

As the adage goes, “There is no certainty like death and taxes.”

While we can’t assist with the former, EWP Financial is here to guide international families in harnessing the potential of PPLI. Discover how we can help you achieve tax compliance, enjoy tax deferral, and secure a tax-free death benefit—all while optimizing your wealth for generations to come.

Contact us today to embark on a journey towards maximizing your tax efficiency through EWP and PPLI.

by Michael Malloy, CLU TEP RFC.
CEO, Founder @EWP Financial

~ Your best source for PPLI and EWP
Michael Malloy CLU TEP RFC

 

 

 

 

 

 

 

 

Taxes, Crypto and PPLI

Taxes, Cryptocurrency and Private Placement Life Insurance

Taxes, Crypto and PPLI

Cryptocurrency is a trending topic and many wealthy individuals find it as a solution for investment gains. We will discuss in this article if Cryptocurrency can be used in conjunction with PPLI for tax savings and to obtain other financial benefits.

We, at EWP Financial, customize solutions using mainly Expanded Worldwide Planning, (EWP) and Private Placement Life Insurance (“PPLI”) to meet the complex needs of our clients. 

PPLI is a versatile type of insurance policy used by super wealthy individuals, sometimes termed a unit-linked policy. The premium can be paid in cash or with a portfolio of bankable assets, but it is also possible to pay with non-traditional asset classes such as art, precious metals or cryptocurrency.

It’s worth noting that even where cryptocurrencies are considered bankable assets, the acceptance and valuation may be subject to certain conditions and requirements. Banks and lenders may have specific criteria, such as the type of cryptocurrency accepted, the liquidity and stability of the market, and the value of the cryptocurrency relative to the loan amount. EWP Financial can advise if you can use cryptocurrency as a bankable asset depending on your particular situation.

What is the role of PPLI?

It’s called Private Placement because each contract is issued under its own private placement memorandum – the policyholder’s assets are segregated from other policyholder’s assets under the same insurance carrier.

Whilst the legal ownership of the assets passes to the insurance carrier, the policyholder retains at all time full rights to request a partial or full surrender of the policy, and change the beneficiaries.  

Why is it difficult to place crypto assets into custody? And why is structuring these assets into a PPLI an effective solution for this?

Cryptocurrencies are not financial assets but an asset class on its own. They also lack physical substance. Therefore, they meet the definition of an intangible asset and would be recorded at acquisition cost (i.e. price paid or consideration given).

Cryptocurrencies are designed to work as a decentralized medium of exchange, independent of a financial institution or any other central authority, so the custody is not with a traditional arrangement of a banking institution but held by a token or key with the key holder having secure access via private passwords or biometric authentication systems.

The difficulty for a cryptocurrency (and other digital assets) is that after the keyholder’s lifetime, if the assets have not been the subject of an inventory with regular updates, then it is very difficult for the executor to identify the deceased’s entire exposure to these digital assets.

Digital assets can be entrusted to professional trustees inter vivos, so that the problem linked to the devolution of the keyholder’s credential is solved. However, many trustees have difficulty custodising such assets due to the associated risks, directly or indirectly that they represent.

By using a PPLI policy to structure the digital assets and appoint the trustee as policyholder, these risks can be mitigated. In addition, the trust can also be the beneficiary of the policy to ensure estate planning over many generations.

What are the tax benefits of holding crypto within a PPLI?

Once the assets are placed within the PPLI, such assets enjoy growth free from income and capital gains tax (as long as there is no partial or full surrender), thus the policy benefits from the gross roll-up effect.

This is especially relevant for cryptocurrencies which are subject to high returns (and lows!). Unstructured cryptocurrencies could be subject to tax on an arising basis in countries like Australia, France, India, Singapore and USA.

“Once your assets are placed into a properly designed EWP Asset Structure, they are shielded from taxation, while simultaneously achieving maximum privacy and asset protection.”  – Michael Malloy CLU TEP RFC

 

by Michael Malloy, CLU TEP RFC.
CEO, Founder @EWP Financial

~ Your best source for PPLI and EWP
Michael Malloy CLU TEP RFC