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Assets
Liabilities
Insurance
Estate
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Summary
Client Information
Client 1
Client 2 (Spouse/Partner)
Household Details
Earned Income
SourceClient 1Client 2
Salary / Wages
Bonus / Commissions
Self-Employment
Deferred Compensation
Total Earned Income $625,000 $275,000
Investment & Passive Income
SourceAnnual Amount
Dividends (Qualified)
Interest Income
Capital Gains (Realized)
Rental Income (Net)
K-1 / Partnership Income
Total Investment Income $525,000
Retirement Income (Current/Projected)
SourceClient 1Client 2Start Age
Social Security
Pension
Annuity Income
Annual Expenses
CategoryAnnual Amount
Living Expenses (Core)
Housing (Mortgage/Rent)
Healthcare / Insurance
Discretionary / Travel
Charitable Giving
Total Annual Expenses $656,000
Income & Expense Summary
$1,425,000
Total Gross Income
$656,000
Total Expenses
$498,000
Est. Tax Liability
$271,000
Annual Surplus
Liquid Assets
Asset TypeValueOwner
Cash & Checking
Savings / Money Market
Taxable Brokerage
Municipal Bonds
Total Liquid $6,450,000
Retirement Accounts
Account TypeClient 1Client 2
401(k) / 403(b)
Traditional IRA
Roth IRA
Deferred Comp Plan
Total Retirement $4,250,000 $1,750,000
Real Estate
PropertyValueMortgageEquity
Primary Residence $2,700,000
Vacation Home $1,800,000
Investment Property $1,500,000
Total Real Estate $7,800,000 $1,800,000 $6,000,000
Business & Alternative Investments
AssetValue% Ownership
Private Business %
Private Equity
Hedge Funds
Collectibles / Art
Total Business/Alt $16,000,000
Total Asset Summary
Liquid Assets $6,450,000
Retirement Accounts $6,000,000
Real Estate Equity $6,000,000
Business & Alternatives $16,000,000
TOTAL NET WORTH $34,450,000
Liquid (19%)
Retirement (17%)
Real Estate (17%)
Business (47%)
Mortgage & Real Estate Debt
LoanBalanceRatePaymentRemaining
Primary Mortgage % yrs
Investment Property % yrs
HELOC %
Other Liabilities
LiabilityBalanceRatePayment
Auto Loans %
Student Loans %
Credit Cards %
Margin Loans %
Other Loans %
Liability Summary
$1,800,000
Mortgage Debt
$500,000
Other Debt
$2,300,000
Total Liabilities
6.7%
Debt-to-Asset Ratio
Life Insurance Coverage
PolicyInsuredTypeDeath BenefitCash ValuePremiumOwner
Policy 1
Policy 2
Policy 3
$8,000,000
Total Death Benefit
$850,000
Total Cash Value
$5,000,000
In ILIT (Estate-Free)
$80,000
Annual Premiums
Disability Insurance
Long-Term Care Insurance
Estate Planning Status
Estate Tax Projections
$23,150,000
Taxable Estate (Fed)
$9,260,000
Federal Estate Tax
$2,640,000
State Estate Tax
$11,900,000
Total Estate Tax
Beneficiary & Legacy Intentions
Liquidity Analysis
Estate Tax Due
$11,900,000
Liquid Assets Available $6,450,000
Insurance in ILIT $5,000,000
Total Liquidity $11,450,000
Liquidity Gap ($450,000)
Additional insurance or estate planning strategies recommended to cover shortfall.
Retirement Goals
Legacy Goals
Education Funding Goals
BeneficiaryCurrent AgeYears to CollegeFunding GoalCurrent Savings
Other Financial Goals
GoalTarget DateAmountPriority
Strategic Planning Framework

John & Jane Smith

Prepared January 6, 2026
$34.5M
Net Worth
$1.4M
Annual Income
$11.9M
Est. Estate Tax
$8M
Life Insurance
Gap
Liquidity Status
Asset Allocation Overview
$34.5M
Total Assets
Liquid 19%
Retirement 17%
Real Estate 17%
Business 47%
Key Metrics
Annual Savings Rate 19%
Debt-to-Asset Ratio 6.7%
Estate Tax as % of Estate 35%
Insurance Coverage Multiple 5.6x Income
Years to Retirement (C1) 2 years
Select Strategy for Analysis

Part 1: Life Insurance as Investment Allocation

Part 2: Life Insurance as Estate Planning Tool

Welcome to Your Planning Resource

This interactive library provides comprehensive education on estate planning strategies, trust structures, and insurance applications. Each topic includes detailed explanations, interactive calculators to model client scenarios, and real-world case studies.

20+
Planning Strategies
8
Trust Types
5+
Interactive Calculators
10+
Case Studies

Quick Start Guide

E

Estate & Trust Library

Learn about ILIT, SLAT, IDGT, Dynasty Trusts and more with interactive calculators

S

Planning Strategies

Investment allocation, estate planning, and business applications

C

Case Studies

Real-world examples with detailed analysis and outcomes

Why Estate Planning Matters

Every client can benefit from estate planning. Proper planning helps maintain family harmony, limits conflicts, and allows clients to pass on a meaningful legacy based on what's important to them. An effective estate plan ensures:

Asset Management
Assets will be managed competently if the client becomes disabled
Controlled Distribution
Estate distributed to beneficiaries exactly as the client decides
Tax Efficiency
Estate distributed in the most tax-efficient manner possible
Reduced Costs
Probate and other estate administration costs minimized
2026 Estate Exemption
$15M
$30M per couple
GST Exemption
$15M
Per person
Estate Tax Rate
40%
On amounts over exemption
Annual Gift Exclusion
$19,000
Per recipient, per year
Capital Needs Analysis

Calculate the life insurance coverage needed to replace income and cover financial obligations.

Human Life Value Calculator

Calculate the economic value of an individual's future earning potential.

Estate Tax Calculator

Estimate federal and state estate tax liability and compare ILIT savings.

Life Insurance Policy Comparison
FeatureTerm LifeWhole LifeVariable LifeIndexed UL
Coverage Period10-30 yearsLifetimeLifetime*Lifetime*
PremiumLevel, LowestLevel, HighestFlexibleFlexible
Cash ValueNoneGuaranteedMarket-based (subaccounts)Index-linked
Death BenefitGuaranteedGuaranteedVariableFlexible
Investment ControlNoneNoneFull (stocks, bonds, funds)Limited (index selection)
Risk LevelLowLowHighMedium
Best ForTemporary needsGuaranteed protectionGrowth-oriented investorsUpside with protection
$1M Premium (Age 40)$600-$900/yr$12,000-$18,000/yr$8,000-$15,000/yr$8,000-$15,000/yr

*Lifetime coverage contingent on adequate premium payments and policy performance.

How These Strategies Work

Life insurance serves as more than just death benefit protection. When properly structured, it becomes a powerful financial planning tool that can:

Tax Diversification

Create tax-free income buckets alongside taxable accounts, reducing lifetime tax burden

Estate Liquidity

Provide immediate cash at death to pay estate taxes without forced asset sales

Asset Protection

Shield wealth from creditors and lawsuits through proper trust structures

Wealth Transfer

Leverage premium dollars into multiples of tax-free death benefit for heirs

The key principle: Every dollar spent on properly structured life insurance can create $3-10 of estate value depending on age, health, and structure.

Part 1: Life Insurance as Investment Allocation

Strategy 1: Tax-Diversification Portfolio Architecture

The Concept: Most affluent clients have concentrated tax exposure—heavy 401(k)/IRA balances (all ordinary income), taxable accounts (capital gains), maybe some Roth. Life insurance creates a third tax bucket: tax-free access.

Specific Implementation:

  • Reallocate 5-15% of fixed income/bond allocation to max-funded IUL or whole life
  • Provides comparable downside protection to bonds but with tax-free upside
  • In retirement, access cash value first while deferring Social Security and letting IRAs grow
  • Create a "personal pension" with tax-free income stream

Example:

Age 55, $5M portfolio, 60% equities/40% bonds ($2M in bonds). Reallocate $750K of bond allocation over 3 years into max-funded IUL. At age 70, client has $1.2M+ accessible tax-free. Compare: $2M bond portfolio earning 4% = $80K income, fully taxable vs. $1M+ insurance cash value = tax-free access + $1.25M death benefit.

The Mathematical Advantage: If client is in 30% tax bracket and earns 6% in taxable account = 4.2% after-tax Same client earning 5% in life insurance = 5% effectively (no tax drag) Over 20 years, the difference compounds significantly
Strategy 2: Alternative Asset Replication via PPLI

The Concept: Private Placement Life Insurance allows high-net-worth clients to hold alternative investments (hedge funds, private equity, real estate) inside a tax-advantaged life insurance wrapper.

The Math That Sells:

Direct Hedge Fund
Investment$5M
15% return x 10 yrs$20.2M
Tax at 40%($8M)
Net to Investor$12.2M
Same Investment in PPLI
Premium$5M
15% return x 10 yrs$20.2M
Tax$0
Net Available$20.2M

Ideal Client Profile: $20M+ net worth, already invested in alternatives, long time horizon (10+ years), high current tax bracket (37% federal + state).

Strategy 3: Concentrated Stock Monetization

The Concept: Executives with concentrated stock positions face massive tax bills if they sell. Life insurance creates immediate liquidity and estate protection without triggering capital gains.

Premium Financing Structure:

  • Client owns $10M concentrated stock position (low basis)
  • Purchase $20M life insurance policy using premium financing
  • Bank loans 90% of premium (collateralized by policy and potentially stock)
  • At death: $20M death benefit pays off loan and creates $10M+ net estate benefit
  • During life: Policy can provide liquidity through loans

The Psychological Win: "Instead of paying $2M to the IRS, you're paying $2M to create $10M of estate protection. You're not spending money—you're repositioning it."

Strategy 4: "Roth Conversion Alternative" for IRA-Heavy Clients

The Concept: Many wealthy clients have massive IRA balances they can't convert to Roth without enormous tax bills. Life insurance creates tax-free estate value without the conversion tax.

The Math:

Traditional Approach
$5M IRA grows to$10M
Kids pay 40% tax($4M)
Net to heirs~$6M
Life Insurance Strategy
Keep $5M IRA, take RMDs$3-4M remains
$2M funds insurance$10M death benefit
Total to heirs$13-14M
Strategy 5: Volatility Buffer for Pre-Retirees

The Concept: Clients 5-10 years from retirement are terrified of sequence-of-returns risk. Life insurance creates a buffer that allows equities to recover during market downturns.

Implementation:

  • Age 55-60, $3M portfolio
  • Fund life insurance with $200K-300K over 3-5 years
  • By retirement (age 65), policy has $350K+ accessible cash value
  • During bear markets, access policy instead of selling stocks
  • During bull markets, let policy and portfolio both grow

Part 2: Life Insurance as Estate Planning Tool

Strategy 6: ILIT - The Estate Tax Eraser

The Concept: For estates over the exemption amount ($15M per person in 2026), 40% federal estate tax applies. Life insurance owned in ILIT passes tax-free and provides liquidity.

Implementation:

  • Create Irrevocable Life Insurance Trust (ILIT)
  • Make annual gifts to trust ($19K per beneficiary in 2026, or use Crummey powers)
  • Trustee uses gifts to pay life insurance premiums
  • Trust owns policy—proceeds NOT included in estate
  • At death, proceeds paid to trust tax-free, provides estate tax liquidity
The Wealth Multiplication Formula: Every dollar spent on insurance creates $3-5 of estate value depending on age and health. This is the highest guaranteed ROI in estate planning.
Strategy 7: SLAT with Life Insurance

The Concept: SLATs allow wealthy couples to remove assets from estate while maintaining indirect access through spouse. Adding life insurance supercharges the strategy.

Implementation:

  • Spouse A creates irrevocable trust for benefit of Spouse B and children
  • Spouse A gifts $10M to trust (uses estate exemption)
  • Trust purchases $20M life insurance on Spouse A (or survivorship)
  • Trust invests remaining $9M+ in diversified portfolio
  • Spouse B can receive distributions from trust during life if needed
  • At death, $20M life insurance proceeds in trust, estate tax-free
Without SLAT
$10M in estate
Grows to $15M
Estate tax at 40%($6M)
Net to heirs$9M
With SLAT + Insurance
$10M gifted to SLAT
$1M buys $20M insurance
$9M grows to $13.5M
Net to heirs$33.5M
Strategy 8: Dynasty Trust with Life Insurance

The Concept: Use life insurance in a dynasty trust to create multi-generational wealth that never faces estate tax again.

The Dynastic Wealth Creation:

Gen 1
$5M premium
$20M insurance
Gen 2
Trust grows
$40M
Gen 3
Continues
$80M
Gen 4
100 years
$160M+

Over 100 years, $5M becomes $160M+ with zero estate/GST tax ever paid. This creates a perpetual wealth machine.

Strategy 9: CRT with Insurance Wealth Replacement

The Concept: Client wants to give to charity but doesn't want to disinherit children. CRT + insurance creates charitable deduction AND replaces inheritance.

Implementation:

  • Transfer $5M appreciated stock to Charitable Remainder Trust
  • CRT sells stock—zero capital gains tax (charity-owned)
  • CRT invests $5M, pays you 5% annually = $250K/year income
  • Receive $2M+ income tax deduction
  • Use tax savings + portion of income to fund $5M life insurance
  • At death: CRT assets go to charity, life insurance goes to kids
Result: You get charitable impact, maximize income, eliminate capital gains tax, AND leave children better off than doing nothing.

Part 3: Life Insurance as Business Tool

Strategy 10: Key Person Insurance

The Concept: Businesses are dependent on key people. Their death can cause revenue loss, client defection, credit problems, and valuation drops.

Calculation Models:

Model A - Salary Replacement

Key salary: $400K
Time to replace: 2 years
Coverage: $800K-1M

Model B - Revenue Dependency

Controls $10M revenue
20% profit margin
Coverage: $2M

Model C - Valuation

Business worth $20M
Key person = 30%
Coverage: $6M

Strategy 11: Buy-Sell Agreement Funding

The Concept: Partners agree that when one dies, the others will buy their shares. Without funding, survivors must come up with cash fast.

Three Buy-Sell Structures:

Cross-Purchase

Each partner owns policy on others. Best for 2-3 partners. Survivor gets step-up in basis.

Entity Purchase

Company owns policies on all partners. Best for 3+ partners. Simpler administration.

Wait-and-See

Company owns policies but partners have rights. Maximum flexibility for tax planning.

Strategy 12: Executive Bonus (§162) Plans

The Concept: Businesses struggle to retain top executives. Executive bonus plans use life insurance to provide golden handcuffs with minimal cost.

Vesting Schedule Example:

Years 1-20% vested (forfeit if leave)
Years 3-525% vested
Years 6-850% vested
Years 9-1075% vested
Year 10+100% vested
$200K Salary Increase
Cost to company$200K/yr
After exec pays 40% tax$120K benefit
10 years$1.2M cost
§162 Bonus Plan
Cost to company$75K/yr
Exec receives$2M life insurance
10 years$750K cost (4.4x better)
Strategy 13: Split-Dollar Life Insurance

The Concept: Company wants to provide executive benefit but doesn't want ongoing costs. Split-dollar allows company to "loan" premiums and recover them later.

Two Primary Structures:

Endorsement Split-Dollar

Company owns policy, pays premiums. Executive has endorsement for portion of death benefit. At death/termination, company recoups premiums.

Collateral Assignment

Executive owns policy. Company loans premiums. Policy collaterally assigned. Loan repaid from proceeds at death.

Net Cost to Company: $0 (recovered all premiums + interest). The time value of money and insurance returns work in everyone's favor.
Strategy 14: Premium Financing for Business Owners

The Concept: Business owners have illiquid wealth in their companies. Premium financing allows them to leverage business cash flow to create personal estate liquidity.

Traditional Purchase
$20M policy
Annual premium$500K
10 years out-of-pocket$5M
Premium Financed
$20M policy
Bank loans 90%$450K/yr
Owner pays interest only~$80K/yr
Risk Disclosure: This strategy works best if the policy performs as illustrated and interest rates remain reasonable. This is a sophisticated strategy requiring ongoing monitoring.

Part 4: Partnership Owned Life Insurance (POLI)

Overview: POLI is a sophisticated nonqualified retirement plan structure designed specifically for professional services partnerships (particularly large law firms). It provides partners with tax-advantaged retirement income through institutionally designed life insurance held in a Special Purpose Entity (SPE).
POLI Program Overview
The Challenge for Big Law Partners
Why Traditional Retirement Planning Falls Short
AM Law 100 PPP
$2.7M+
AM Law 50 PPP
$4.1M+
Max 401(k) DB Balance
$3.1M
Annual DC Limit (50+)
$67,500

The Problem: IRS limits on qualified retirement plan deferrals force high-income partners to save on an after-tax basis. Nonqualified plans create balance sheet liabilities that new partners inherit, and the pass-through tax treatment makes traditional COLI strategies cost-prohibitive.

The POLI Solution

Tax-Free Growth

Contributions invested in life insurance grow tax-free. Similar to Roth IRA treatment but with no contribution limits.

Tax-Free Distributions

Retirement income paid via policy loans and death benefits—completely tax-free to participants.

No Balance Sheet Impact

SPE structure keeps program separate from firm. No liability passed to incoming partners.

Bankruptcy Remote

Benefits not subject to continued operation of the firm. Protected from firm creditors.

How POLI Works: Program Mechanics

POLI Cash Flow Structure

Partners
After-Tax Contributions
$50K-$200K/yr avg
SPE
Special Purpose Entity
Delaware Partnership
Life Insurance
GSI Policies
PPLI + IUL
Tax-Free Income
7-8%+ IRR
10-20 yr distributions
Optional Leverage: J.P. Morgan Private Bank financing (40-50% of premiums) to enhance returns

Step-by-Step Process

1
SPE Formation
Delaware-based SPE created, classified as partnership for tax purposes. Partners enter into partnership agreement.
2
Policy Acquisition
SPE purchases guaranteed standard issue (GSI) life insurance on participating partners. No medical underwriting under age 70.
3
Contributions & Investment
Partners make after-tax contributions (5-7 years typical). SPE Investment Committee selects portfolio design. Optional bank financing enhances premiums.
4
Tax-Free Growth
Policy cash values grow tax-free. Target returns credited to participant accounts (typically 7% target).
5
Tax-Free Distributions
After minimum 10-year period, participants receive tax-free income via policy loans and death benefit recoveries.
Investment Structure & Target Returns

The SPV Investment Committee selects the portfolio design, which drives the target return for participants. A typical 65/35 allocation provides strong risk-adjusted returns:

65% Private Placement Life Insurance (PPLI)
Investment OptionsS&P 500, Equity Funds
Average Gross Return9.72%
All-In Net Expense~100 bps
Average Net Return8.72%
35% Indexed Universal Life (IUL)
Index StrategyUncapped S&P Funds
Average Gross Return6.24%
All-In Net Expense~50 bps
Average Net Return5.74%
Projected Plan Returns (Non-Leveraged Example)
7.68%
Blended Portfolio Return
8.41%
With Death Benefit Recovery
7.00%
Target Crediting Rate
1.41%
Plan Excess Buffer
Participant Benefit Examples

The following examples assume a 7% target return, $500K total contribution over 5 years, and a 29.5% blended capital gains tax rate for taxable equivalent calculations:

Entry Age Benefit Start Distribution Period Annual Income Total Benefit Tax-Equiv Return
45 years old Age 65 20 years $148,500/yr $2,970,000 10.02%
50 years old Age 65 20 years $103,500/yr $2,173,500 10.01%
55 years old Age 70 20 years $103,500/yr $2,173,500 10.01%
60 years old Age 70 20 years $74,000/yr $1,554,000 10.01%
65 years old Age 75 15 years $85,000/yr $1,360,000 10.02%
Tax Advantage: A 10% tax-free return is equivalent to approximately 14% in a traditional IRA (taxed as ordinary income at 37%+) or 12.5% in a taxable account (at 29.5% cap gains). POLI effectively creates a "super-charged Roth IRA" with no contribution limits.
Premium Financing Option

POLI programs can utilize premium financing from private banks (typically J.P. Morgan) to enhance returns through leverage arbitrage:

Financing Mechanics
  • Bank finances 40-50% of total policy premiums
  • Rates: SOFR + 140-200 bps depending on tenor
  • Line of credit with maturities up to 5 years
  • Interest-only payments, principal due at maturity
Collateral Structure
  • Up to 95% LTV on guaranteed CSV
  • Carrier must have A+/A1 rating minimum
  • Loans non-recourse to the firm
  • Repaid through policy proceeds
Risk Considerations: Leverage amplifies both gains and losses. Interest rate fluctuations, market volatility, and potential collateral shortfalls must be monitored. Premium financing is optional—unleveraged POLI still provides compelling tax-free returns.
Benefits to Firm & Partners
Benefits to the Firm
Retention toolNo balance sheet liability
Non-qualified planNo discrimination testing
Financial riskBorne by participants
Vesting schedulesCan be built in for retention
Any loan financingNon-recourse to firm
Benefits to Partners
Tax treatmentSimilar to Roth IRA
Contribution limitsNone (vs. $67.5K qualified)
UnderwritingGSI—no medical under 70
Asset protectionBankruptcy remote
Target return7-8%+ tax-free (10%+ equiv)
Plan Design & Voluntary Features

Participation

  • Limited to US Partners/Shareholders only
  • One-time "yes or no" election to participate
  • Cannot opt-in after program established (tax rules)
  • New SPV created every few years for new partners
  • Existing partners can elect into new SPV as well

Contributions

  • Maximum based on combined group insurance capacity
  • One-time election for set contribution period (5-7 years)
  • SPV Committee communicates target return
  • Can continue contributions even if leaving firm
  • Average range: $50,000 - $200,000 per year

Distributions

  • Minimum 10-year period before distributions
  • Flexible payout periods: 10, 15, or 20 years
  • Option to defer start as late as age 80
  • Death: full value paid to beneficiaries
  • Residual SPE assets distributed at end of lifecycle

Taxation

  • Contributions: After-tax (like Roth)
  • Investment growth: Tax-free (IRC §7702)
  • Credited returns: Tax-free
  • Distributions: Fully tax-free
  • Death benefits: Tax-free to SPE
Implementation Timeline

POLI implementation typically takes 9-12 months from feasibility study through launch:

Months 1-2
Feasibility Study

Firm objectives assessment, pro forma projections, qualitative risk analysis, workstream coordination (tax, actuarial, insurance, financing, structuring)

Months 3-5
Plan Design

Finalize contribution requirements, distribution options, vesting schedules, investment committee structure, SPE documentation

Months 6-8
Partner Education & Elections

Partner communications, webcasts, projection tools, indicative elections, final commitment collection

Months 9-12
Implementation

Insurance broker coordination, bank financing (if elected), policy issuance, SPE funding, ongoing administration setup

Market Adoption: Since 2020, five prominent law firms have implemented POLI programs, with six additional firms in active plan design as of recent reporting. The strategy has proven particularly attractive for AM Law 100 firms seeking competitive partner benefits.
Firm-Sponsored Informal Funding Alternative

Some firms offer nonqualified deferred compensation plans that create unfunded liabilities. POLI can also be used to informally fund these firm-sponsored benefits:

Firm-Sponsored POLI Structure

90-95%
Bank Loan of Premiums
5-10%
Firm Contribution
Minimal
Cash Flow Impact

How It Works

  • Firm purchases GSI life insurance on participating partners
  • Bank loans 90-95% of premiums; firm funds remainder
  • Policies build tax-free cash values to fund retirement benefits
  • Tax-free death benefits recover additional benefit expenses
  • Creates additional security for retiring partners
  • Reduces reliance on working partners funding retired partner benefits
Important Disclosures

This information is for educational purposes only and does not constitute tax, legal, or investment advice. POLI strategies involve complex tax, insurance, and financing considerations that require consultation with qualified advisors. Policy cash value IRRs and target returns are not guaranteed and may vary depending on underlying portfolio returns, market conditions, and insurance carrier performance.

Life insurance policy obligations are backed solely by the insurance carrier's claims-paying ability. Values shown are illustrative and based on current non-guaranteed assumptions. IRC Section 7702 and 7702A govern the tax treatment of life insurance contracts. Loans and lines of credit are extended at the discretion of participating banks and are subject to credit approval.

Contact: For more information about POLI programs, contact Vanbridge Life & Executive Benefits.

How to Use This Library: Each trust type below includes educational content explaining how it works, plus an interactive calculator where you can input your client's specific situation to see projected outcomes. Use this to educate yourself and model planning scenarios before client meetings.
2026 Estate Exemption
$15M
$30M per couple
GST Exemption
$15M
Per person
Estate Tax Rate
40%
On amounts over exemption
Annual Gift Exclusion
$19,000
Per recipient, per year

Irrevocable Life Insurance Trust (ILIT)

Most Common

The ILIT removes life insurance proceeds from your client's taxable estate while providing immediate liquidity to pay estate taxes, debts, and provide for heirs. It's the cornerstone of estate liquidity planning.

ILIT Structure & Cash Flow
GRANTOR Annual Gifts $76K/yr ILIT Irrevocable Trust Owns Policy Crummey Notices Premiums INSURANCE COMPANY Policy Issued Death ILIT RECEIVES $10M TAX-FREE BENEFICIARIES Protected from: • Creditors • Divorce • Estate Tax OUTSIDE TAXABLE ESTATE — SAVES 40% ESTATE TAX
How It Works
1
Create the Trust
Attorney drafts irrevocable trust. Select independent trustee (not insured). Name beneficiaries.
2
Trust Acquires Policy
Trustee applies for new policy OR existing policy transferred (triggers 3-year rule).
3
Annual Gifts Fund Premiums
Grantor gifts premium amount to trust. Crummey notices sent to beneficiaries (30-day window).
4
Tax-Free Proceeds at Death
Death benefit paid to trust, not estate. Zero estate tax on proceeds. Trustee distributes per terms.
Key Benefits
✓ Estate Tax Savings
Death benefit excluded from taxable estate (saves 40% tax on proceeds)
✓ Immediate Liquidity
Cash available within days of death to pay taxes, debts, provide income
✓ Asset Protection
Proceeds protected from beneficiaries' creditors and divorce
✓ Leverage
Small annual premiums create large tax-free death benefit (often 10:1 or better)
Crummey Powers Explained

For gifts to qualify for the annual exclusion, beneficiaries must have a "present interest" (immediate access). Crummey powers solve this:

  • Written Notice Required: Within 30 days of contribution, send formal notice to each beneficiary
  • Withdrawal Right: Beneficiaries have 30-60 days to withdraw their share (up to $19K each)
  • Practical Reality: Beneficiaries rarely withdraw—doing so would jeopardize future gifts and family planning
  • Documentation Critical: Keep copies of all notices, delivery proof, and trust accounting

Spousal Lifetime Access Trust (SLAT)

Post-Sunset Planning

The SLAT allows married couples to remove assets from their taxable estate while maintaining indirect access through the spouse beneficiary. With the 2026 exemption at $15M per person ($30M married), SLATs remain a powerful tool for estates exceeding these thresholds to lock in tax-free transfers.

SLAT Structure — Maintain Access While Removing from Estate
SPOUSE A (Grantor) Creates Trust $15M Gift SLAT Spousal Lifetime Access Trust Independent Trustee HEMS SPOUSE B (Beneficiary) Income Access Indirect access through spouse CHILDREN/DESCENDANTS Ultimate Beneficiaries ESTATE BENEFITS ✓ Out of both estates ✓ Growth excluded ✓ Uses exemption now ⚠ CAUTION Reciprocal Trust Doctrine Risk
How It Works
1
One Spouse Creates Trust
Donor spouse creates irrevocable trust naming other spouse + descendants as beneficiaries.
2
Fund with Exemption
Transfer up to $15M (2026) using lifetime gift exemption. No gift tax due.
3
Spouse Accesses Funds
Beneficiary spouse can receive distributions for health, education, maintenance, support (HEMS).
4
Assets Grow Outside Estate
All growth excluded from both spouses' estates. Passes to children tax-free.
Critical Warning: Reciprocal Trust Doctrine

If both spouses create identical SLATs for each other, IRS may "uncross" them, treating each spouse as grantor of their own trust. To avoid this:

  • Different funding amounts (e.g., $10M vs $8M)
  • Different trustees
  • Different distribution standards
  • Create trusts at different times
Current Tax Environment
2026 Exemption
$15M
Per Couple
$30M

The Opportunity: With generous exemptions, SLATs enable couples to transfer substantial wealth while maintaining indirect access. Lock in transfers now before any future legislative changes.

Key Benefits
✓ Use High Exemption
Transfer up to $15M per spouse tax-free
✓ Maintain Indirect Access
Spouse can receive distributions—unlike regular irrevocable trusts
✓ All Growth Excluded
Transfer $10M today, grows to $25M—entire amount escapes estate tax
✓ Asset Protection
Protected from creditors, lawsuits, divorce of beneficiaries

Intentionally Defective Grantor Trust (IDGT)

Estate Freeze

The IDGT is a powerful estate freeze technique. The "defect" is intentional—it makes the trust a grantor trust for income tax purposes but NOT for estate tax purposes. This allows the sale of appreciating assets to the trust without triggering capital gains, while all future appreciation passes to beneficiaries tax-free.

IDGT Installment Sale — Freeze Value, Transfer Growth
GRANTOR Owns $10M Asset (Low Basis) Pays Trust's Tax 1. SEED $1M 2. SELL $9M for Note IDGT Intentionally Defective Grantor Trust Owns $10M asset 3. Note Payments (AFR) Growth APPRECIATION $20M+ Escapes Estate BENEFICIARIES Estate Tax Free KEY BENEFITS ✓ No capital gain on sale ✓ Value frozen at AFR rate ✓ Grantor pays trust income tax (additional tax-free gift) ✓ All growth above AFR transfers to beneficiaries ✓ Outside taxable estate
How It Works
1
Create Trust with "Defect"
Include provision like power to substitute assets. This makes it a grantor trust for income tax only.
2
Seed the Trust
Make initial gift of ~10% of sale amount. This gives trust substance for installment sale.
3
Sell Assets for Note
Sell appreciating assets for promissory note at AFR. No capital gain recognized (same taxpayer).
4
Growth Escapes Estate
All appreciation above AFR rate passes to beneficiaries. Grantor pays income tax (additional gift).
Why "Defective"?

The trust is "intentionally defective" because it's treated as owned by the grantor for income tax purposes (grantor pays all income taxes) but is a completed gift for estate tax purposes (assets excluded from estate). This "defect" is actually a powerful planning feature.

Key Benefits
✓ Estate Freeze
Value frozen at sale price—all appreciation passes to beneficiaries tax-free
✓ No Capital Gains Tax
Sale to grantor trust is not a taxable event (Rev. Rul. 85-13)
✓ Additional Tax-Free Transfer
Grantor paying trust's income tax = additional gift without using exemption
✓ Leveraged Arbitrage
If assets grow faster than AFR, excess passes tax-free
Ideal Candidates
  • Business owners with appreciating company stock
  • Real estate investors with low-basis properties
  • Tech executives with concentrated stock positions
  • Anyone with assets expected to significantly appreciate

Dynasty Trust

Multi-Generational

A Dynasty Trust is designed to last for multiple generations (potentially perpetually in some states), acting as a "family bank" that provides funds for education, medical needs, business ventures, and home purchases—while avoiding estate and GST tax at every generational transfer.

Dynasty Trust — Multi-Generational Wealth Preservation
GRANTOR Funds $15M GST Exempt DYNASTY TRUST Perpetual • SD/NV/DE Protected • Tax-Free $15M → $500M+ GEN 1: Children HEMS Access GEN 2: Grandkids HEMS Access GEN 3: Great HEMS Access GEN 4+: Perpetual Continues Forever 100-YEAR COMPARISON DYNASTY TRUST $500M+ 0% Estate Tax OUTRIGHT $28M 40% Tax × 4 Gens DYNASTY ADVANTAGE 18x MORE WEALTH Best States: SD • NV • DE • AK No Rule Against Perpetuities HEMS Distributions Available Each Generation • No Estate Tax Ever
How It Works
1
Establish in Favorable State
South Dakota, Nevada, Delaware, Alaska allow perpetual trusts with strong asset protection.
2
Fund with GST Exemption
Use $15M GST exemption (2026) to fund trust. Consider leveraging with life insurance.
3
Provide for Descendants
Distributions available for health, education, maintenance, support (HEMS). Can include discretionary distributions.
4
Grows Tax-Free Forever
No estate tax at any generation. Trust continues for grandchildren, great-grandchildren, and beyond.
The "Family Bank" Concept

Think of a dynasty trust as a perpetual family bank. Rather than distributing wealth outright (where it's exposed to estate tax, creditors, divorce), the trust holds assets for the benefit of all future generations, making loans or distributions as needed while maintaining asset protection.

Key Benefits
✓ Perpetual Estate Tax Avoidance
Assets never included in any descendant's estate—40% savings each generation
✓ GST Tax Avoidance
Skip-person transfers without additional 40% GST tax
✓ Asset Protection
Protected from beneficiaries' creditors, divorcing spouses, lawsuits
✓ Professional Management
Corporate trustee ensures consistent management across generations
Favorable Jurisdictions
South DakotaPerpetual, no state income tax
Nevada365 years, no state income tax
DelawarePerpetual, strong privacy
Alaska1,000 years, self-settled trusts

Beneficiary Defective Inheritor's Trust (BDIT)

Control + Protection

An irrevocable trust that lets you access and control assets while shielding them from estate taxes and creditors. Unlike self-settled trusts, the BDIT is created by a third party (typically a parent), giving it superior creditor protection that's recognized nationwide.

BDIT + Insurance LLC — Control, Protection & Access
PARENT (Settlor) Seeds $10K Creates BDIT Beneficiary Defective Inheritor's Trust You = Managing Trustee YOU (Beneficiary) High Income LOAN $250K/yr AFR Owns INSURANCE LLC You = Manager Holds Policy VUL/PPVUL/IUL LIFE INSURANCE Cash Value $8.5M Tax-Deferred TAX-FREE POLICY LOANS: $300K/year Access AT DEATH $10M+ to Dynasty Trust Estate Tax FREE PROTECTIONS ✓ Creditor Protected ✓ Outside Estate ✓ You Control 15 Yrs Funding $3.75M Total Loans $8.5M Cash Value $300K Annual Access
Core Mechanics
1
Third-Party Creation
Parent or trusted individual creates and seeds the trust ($5K-$10K initial gift). Self-funding is prohibited.
2
Beneficiary Control
You serve as managing trustee with control over investments. Independent trustee approves distributions.
3
Defective Tax Status
Trust is a grantor trust to the settlor (parent). Income reported on their return, not yours.
4
Loan to Trust
You loan funds to BDIT at AFR. Trust invests in assets or insurance. Access via bona fide secured loans.
BDIT + Insurance LLC Structure

The BDIT owns an Insurance LLC which purchases high cash value life insurance (VUL, PPVUL, IUL). You manage the LLC and access cash value via policy loans or LLC distributions. At death, proceeds pass estate-tax free to your descendants.

Key Benefits
✓ Liquidity
Access trust assets via loans, enabling tax-free retirement income through policy loans
✓ Estate Exclusion
Since you don't create or fund the BDIT, assets remain outside your taxable estate
✓ Creditor Protection
Strong nationwide protection—superior to DAPTs in non-favorable states
✓ Control
Full managerial authority as trustee and LLC manager
✓ Tax Efficiency
Tax-deferred growth; loan interest may be deductible
BDIT vs. DAPT Comparison
FeatureBDITDAPT
CreatorThird-partySelf-settled
Beneficiary ControlHighModerate
Estate ExclusionYesUsually
Creditor ProtectionNationwideState-dependent
JurisdictionAny stateNV, DE, etc.
Ideal Candidates
Entrepreneurs
Executives
Professionals
High Liability Risk

Grantor Retained Annuity Trust (GRAT)

Purpose: Transfer appreciation on assets to heirs with minimal or zero gift tax.

How It Works:
Key Benefits:

Asset Transfer with Control Strategies

Advanced Planning

These strategies enable clients to transfer wealth and provide beneficiaries with balance sheet strength while retaining meaningful control over assets. Ideal for complex family situations, business succession, and scenarios requiring flexibility.

Family LLC Structure — Control vs. Economic Interest
CLIENT Assets: $20M KEEPS CONTROL Manager/GP Contributes $20M FAMILY LLC or Family Limited Partnership Valuation Discounts: 20-40% $20M → $12-16M for gift tax VOTING 1% Control Shares NON-VOTE 99% Economic 1% Voting → Client (Full Control) BENEFICIARIES Receive Non-Voting Economic Shares PARTNER: 19% Net Worth: $3.8M CHILDREN: 80% Via Dynasty Trusts RESULT On Paper: Ownership | Reality: Client Controls KEY BENEFITS ✓ Control ✓ 20-40% Discount ✓ Growth Shifts ✓ Any State CONTROL RETAINED ✓ Manager/GP powers ✓ Investment decisions ✓ Distribution timing ✓ Operating agreement PASS-THROUGH TAX Income flows to members' returns
The Core Challenge

Many clients face a common dilemma: they want to transfer wealth for estate planning purposes, but aren't ready to give up control. These strategies solve the "have your cake and eat it too" problem—transferring assets while maintaining decision-making authority.

Primary Strategies
1
Family LLC / FLP
Contribute assets to entity. Retain voting/control shares as manager. Transfer non-voting economic shares to beneficiaries. They show ownership on balance sheet; you make all decisions.
2
IDGT (Intentionally Defective Grantor Trust)
Sell or gift assets to trust. Retain indirect control via trustee selection and asset substitution powers. Trust is outside estate but you pay income tax (additional tax-free gift).
3
GRAT (Grantor Retained Annuity Trust)
Fund trust, receive annuity payments back during term. Remainder passes to beneficiaries. You maintain cash flow; they get future appreciation.
4
SLAT (Spousal Lifetime Access Trust)
Transfer assets to irrevocable trust for spouse. Assets protected from creditors and removed from estate. Spouse receives distributions; you have indirect access.
Key Benefits Across Strategies
✓ Maintain Control
Retain voting rights, management authority, or trustee selection powers
✓ Estate Tax Reduction
Remove appreciation from taxable estate while freezing current values
✓ Asset Protection
Shield assets from creditors, lawsuits, and financial risks
✓ Valuation Discounts
LLC/FLP structures allow minority and lack of marketability discounts (20-40%)
✓ Flexibility
Change beneficiaries, adjust distributions, adapt to family circumstances
Advanced Wrapper Structures

LLC + Pledge Agreement: Beneficiary owns non-voting shares but pledges them back under private contract, creating leverage while showing balance sheet ownership.

Intra-Family Loans: Make loans to beneficiaries at AFR. They show assets on balance sheet; you maintain economic leverage via debt.

Trust + Letter of Wishes: Create trust with independent trustee who follows your non-binding guidance. Retain power to replace trustee.

Decision Framework

Want beneficiary to "own" something now? → LLC/FLP
Want tax leverage to transfer wealth? → IDGT or GRAT
Want optics of net worth with strings? → Trust with substitution powers

Philanthropic & Charitable Planning

Tax-Smart Giving

Integrate life insurance, annuities, and philanthropic structures to maximize charitable impact while protecting family wealth. Think of charity as a "tax absorption partner"—give tax-heavy assets to charity, keep tax-efficient assets for family.

CRT + Insurance Wealth Replacement — The Self-Sustaining Flywheel
CLIENT $2M Stock Basis: $200K 1. CONTRIBUTE CRT Charitable Remainder Trust Sells Tax-Free! 2. SELLS No Cap Gains! INVESTS FULL $2,000,000 No tax haircut 3. INCOME: $100K/year (5%) TAX DEDUCTION $600K Saves $222K 4. FUND ILIT ILIT $2M Policy $20K/yr premium 5. AT DEATH FAMILY RECEIVES $2,000,000 TAX-FREE CHARITY RECEIVES $2M+ Remainder CRT at termination NET RESULT Client: +$21K/yr more income Tax Savings: $222K immediate Family: $2M tax-free death benefit Charity: $2M+ endowment Everyone Wins!
Core Strategies
1. Wealth Replacement Trust (WRT)

Give to charity without disinheriting family. Make charitable gift → get tax deduction → use savings to fund ILIT → insurance replaces gifted amount for heirs. Net cost to family: $0.

2. CRT + Life Insurance

Turn appreciated assets into income. Contribute to CRT → CRT sells tax-free → pays you income for life → remainder to charity → insurance replaces asset for heirs. Eliminates capital gains tax.

3. Charitable Gift Annuity (CGA)

Simpler than CRT. Gift to charity → receive guaranteed fixed annuity for life → partial tax deduction → part of each payment is tax-free return of principal. No trust administration required.

4. Donor-Advised Fund (DAF)

Get deduction now, decide on charities later. Contribute cash or appreciated stock → immediate deduction → assets grow tax-free → advise on grants anytime → successor advisors continue legacy.

5. Testamentary Asset Location

Match tax-inefficient assets to tax-exempt recipients. Leave IRA/401(k) to charity (pays no tax) → leave stepped-up basis assets to family → insurance provides additional tax-free inheritance.

Tax Character Hierarchy

Route tax-heavy assets to charity, tax-light assets to family:

IRA/401(k)100% taxed to heirs→ CHARITY
Deferred AnnuityGain taxed as ordinary→ CHARITY
Appreciated StockStep-up at death→ FAMILY
Roth IRA100% tax-free→ FAMILY
Life Insurance100% tax-free→ FAMILY
The Three-Hedge System
✓ Annuity: Solves longevity risk (income for life)
✓ Insurance: Solves mortality risk (creates wealth at death)
✓ Charity: Solves tax risk (absorbs tax friction)
CRT Types
CRAT

Fixed $ annually
No additions allowed
Better for lower returns

CRUT

Fixed % annually
Additions allowed
Payments can grow

CRT Rules: Min 5% payout, max 50%. Remainder must be ≥10% of contribution. Cannot hold S-corp stock.

Advanced Strategies
Philanthropic ILIT

Name charity as beneficiary of ILIT. Guaranteed endowment regardless of market performance.

QCD Strategy

Qualified Charitable Distribution from IRA (age 70½+). Satisfies RMD without adding taxable income.

Synthetic Philanthropic Roth

Roth conversion + DAF contribution. Charitable deduction offsets conversion tax.

Qualified Personal Residence Trust (QPRT)

Purpose: Transfer personal residence to heirs at discounted gift tax value while retaining right to live in home.

How It Works:
Key Benefits:
Trust Comparison Matrix
Trust TypePrimary PurposeGift Tax ImpactEstate Tax ImpactBest For
ILITLife insurance outside estateAnnual exclusion giftsProceeds excludedEstate tax liquidity
SLATAccess + estate removalUses exemptionAssets excludedCouples wanting flexibility
IDGTFreeze appreciating assetsSeed gift onlyFreezes valueBusiness owners, stock holders
DynastyMulti-generational wealthUses GST exemptionPerpetually excludedLong-term family wealth
BDITControl + protection + accessThird-party seed giftExcluded from beneficiary estateHigh-liability professionals
CRTIncome + charitable giftImmediate deductionRemainder to charityAppreciated assets, income need
GRATZero-gift asset transferZero/minimalAppreciation excludedHigh-growth assets
QPRTTransfer residenceDiscountedExcluded at term endValuable real estate
LLC/FLPControl + valuation discounts20-40% discountsFreezes value; shifts growthBusiness succession, control
The Johnson Family: $40M Estate Tax Challenge
Navigating a $10.4M Tax Gap to Protect Family Wealth
Net Worth
$40M
Family Business
$18M
Real Estate
$12M
Liquid Assets
$8M
Estate Tax Due
$10.4M

The Challenge

Robert and Susan Johnson have a $40M estate including an $18M family business and $12M in real estate. Their liquid assets of $8M fall short of the $10.4M estate tax liability, creating a $2.4M+ liquidity gap that could force sale of the family business.

The Solution: ILIT with Survivorship Policy

The Martinez Family: $75M Tech Concentration
Navigating Concentration Risk and Hefty Tax Liabilities
Net Worth
$75M
Tech Stock
$40M
Cost Basis
$3M
Cap Gains if Sold
$8M+
Estate Tax Exposure
$24.4M

The Challenge

Carlos Martinez has $40M in tech stock with a $3M basis. Selling triggers $8M+ in capital gains. Estate tax exposure is $24.4M. Concentration risk threatens long-term growth and financial stability.

The Solution: IDGT + ILIT Combination

Dr. Patel: S-Corp + Executive Bonus Strategy
Business-Funded Life Insurance for Medical Practice Owner
Practice Revenue
$3.2M
Personal Income
$800K
Net Worth
$12M
Insurance Need
$5M

The Challenge

Dr. Patel owns a successful medical practice structured as an S-Corp. He needs $5M life insurance for estate planning but wants to use pre-tax business dollars rather than personal after-tax income.

The Solution: S-Corp Bonus to ILIT

Module 1
Estate Planning Fundamentals
  • Estate tax structure and rates
  • Federal exemption amounts
  • The three wealth transfer challenges
  • Basic planning building blocks
Module 2
Trust Structures Deep Dive
  • ILIT mechanics and funding
  • Crummey powers explained
  • SLAT and IDGT strategies
  • Dynasty trust planning
Module 3
Advanced Funding Strategies
  • Split-dollar arrangements
  • Premium financing structures
  • PPLI and PPVA
  • Captive insurance strategies
Module 4
Business Applications
  • Key person insurance
  • Buy-sell agreement funding
  • Executive bonus plans
  • Deferred compensation
IRS Tax Code Reference

Key tax code sections that shape estate and insurance planning strategies:

SectionTitlePlanning Application
§101(a)Death Benefit ExclusionLife insurance proceeds generally income tax-free to beneficiary
§101(j)Employer-Owned Life InsuranceNotice and consent requirements for EOLI; limitations on tax-free treatment
§2042Proceeds in EstateIncludes proceeds in estate if decedent had "incidents of ownership"; ILIT planning
§20353-Year RulePolicies transferred within 3 years of death included in estate
§§671-679Grantor Trust RulesDetermines when grantor taxed on trust income; IDGT planning
§7872Below-Market LoansAFR requirements for intra-family and split-dollar loans
§2701-2704Valuation RulesFLP/LLC valuation; preferred partnership freeze requirements
§7702/7702ALife Insurance DefinitionDefines policy qualification; MEC rules and testing
§72(e)DistributionsTax treatment of policy loans and withdrawals
§162Business ExpensesDeductibility of executive bonus and compensation payments
§409ADeferred CompensationNQDC timing and structure requirements
§664CRT RulesCharitable remainder trust requirements and taxation
§2055Charitable DeductionEstate tax deduction for charitable bequests
Document Templates
Crummey Notice Template
NOTICE OF RIGHT TO WITHDRAW
[Name of Trust]

Date: _________________

To: [Beneficiary Name]
[Address]

Dear [Beneficiary Name]:

You are hereby notified that a contribution in the amount of $_________________ has been made to the [Trust Name] (the "Trust") on [Date].

As a beneficiary of the Trust, you have the right to withdraw from the Trust an amount equal to the lesser of:

(a) The amount of the contribution, or
(b) Your proportionate share of the annual exclusion amount ($19,000 for 2026)

This right of withdrawal will lapse if not exercised within thirty (30) days from the date of this notice.

To exercise your right of withdrawal, you must deliver written notice to the Trustee at the address below within the withdrawal period.

Trustee: _______________________
Address: _______________________
Phone: _______________________

Very truly yours,

_______________________
Trustee

IRC §101(j) Notice & Consent Form
EMPLOYER-OWNED LIFE INSURANCE
NOTICE AND CONSENT FORM

(Required under IRC §101(j))

NOTICE TO EMPLOYEE

This notice is provided to you pursuant to Internal Revenue Code Section 101(j). Please read carefully and sign below.

1. Intent to Insure: [Employer Name] ("Employer") intends to purchase life insurance on your life.

2. Maximum Face Amount: The maximum face amount for which the Employer may insure your life is $_________________.

3. Beneficiary: The Employer will be a beneficiary of any proceeds payable upon your death under the policy.

4. Coverage Continuation: This insurance coverage may continue after you terminate employment with the Employer.


EMPLOYEE CONSENT

I acknowledge that I have received this notice and I hereby consent to being insured under a life insurance policy owned by the Employer.

Employee Signature: _______________________
Print Name: _______________________
Date: _______________________

Buy-Sell Agreement Insurance Addendum
INSURANCE FUNDING ADDENDUM
TO BUY-SELL AGREEMENT

This Addendum is made as of _____________, 20___, by and between the parties to the Buy-Sell Agreement dated _____________.

1. INSURANCE POLICIES

The following life insurance policies shall be maintained to fund the purchase obligations:

InsuredOwnerBeneficiaryFace Amount
______________________________$__________
______________________________$__________

2. PREMIUM PAYMENTS

Premiums shall be paid by: [ ] Entity [ ] Cross-Purchase

3. POLICY OWNERSHIP UPON TERMINATION

If an owner withdraws, policies on such owner's life shall be: [ ] Transferred to insured [ ] Surrendered [ ] Other

Split-Dollar Agreement Template
COLLATERAL ASSIGNMENT SPLIT-DOLLAR
LIFE INSURANCE AGREEMENT

This Agreement is entered into as of _____________, 20___, by and between:

EMPLOYER: _______________________ ("Company")
EMPLOYEE: _______________________ ("Executive")

1. POLICY
The Company shall pay premiums on Policy No. _____________ issued by _____________ on the life of the Executive.

2. OWNERSHIP
The Executive (or Executive's trust) shall own the Policy, subject to the Company's collateral assignment.

3. PREMIUM PAYMENTS
The Company shall pay all premiums due on the Policy. Such premium payments shall be treated as loans under Treas. Reg. §1.61-22.

4. INTEREST
Interest shall accrue on the outstanding loan balance at the applicable federal rate (AFR).

5. REPAYMENT
The loan balance shall be repaid upon: (a) termination of employment, (b) surrender of Policy, or (c) death of Executive.

Annual Policy Review Checklist
ANNUAL POLICY REVIEW CHECKLIST

Client: _______________________ Date: _____________

Policy: _______________________ Carrier: _____________


POLICY PERFORMANCE

  • Review current cash value vs. original illustration
  • Compare current death benefit to projected
  • Analyze current crediting rate/index performance
  • Review cost of insurance charges vs. projected
  • Check policy loan balance and interest rate

FUNDING STATUS

  • Verify premium payment history
  • Project policy sustainability at current funding
  • Review against 7702/MEC limits

OWNERSHIP & BENEFICIARY

  • Confirm policy ownership is correct
  • Review beneficiary designations
  • Check for any ownership changes needed
Suitability Documentation Form
INSURANCE RECOMMENDATION
SUITABILITY DOCUMENTATION

CLIENT INFORMATION

Name: _______________________ Age: _____ Health: [ ]Excellent [ ]Good [ ]Fair

Annual Income: $_____________ Net Worth: $_____________ Liquid Assets: $_____________

INSURANCE NEED IDENTIFIED

[ ] Income replacement [ ] Estate liquidity [ ] Business succession
[ ] Key person protection [ ] Wealth transfer [ ] Retirement supplement

PRODUCT RECOMMENDED

Type: [ ]Term [ ]Whole Life [ ]UL [ ]IUL [ ]VUL [ ]Second-to-Die
Face Amount: $_____________ Annual Premium: $_____________

SUITABILITY FACTORS CONSIDERED

  • Client's stated objectives align with recommendation
  • Premium is affordable based on income/assets
  • Coverage amount appropriate for identified need
  • Product features match client's risk tolerance
  • Existing coverage reviewed and considered
Compliance Guide

Key Compliance Requirements

ILIT Administration Requirements
  • Crummey Notices: Must be sent within reasonable time of each contribution (30 days typical)
  • Withdrawal Period: Beneficiaries must have actual opportunity to withdraw (typically 30-60 days)
  • Documentation: Maintain copies of all notices, proof of mailing, and beneficiary acknowledgments
  • Trust Accounting: Annual statements to beneficiaries recommended
  • Premium Payment: Trustee should pay premiums from trust account, not directly from grantor
Split-Dollar Compliance
  • Written Agreement: Required before policy inception or first premium payment
  • Regime Election: Must be clear whether loan or economic benefit regime applies
  • Interest Rate: Loan regime requires AFR or higher; document rate used
  • Collateral Assignment: File with carrier; maintain executed copy
  • Annual Reporting: Track imputed interest (loan regime) or economic benefit (EB regime)
§101(j) Requirements (EOLI)
  • Notice: Written notice to employee BEFORE policy issuance
  • Content: Must state employer intends to insure employee's life and maximum face amount
  • Consent: Employee must provide written consent to being insured
  • Timing: Notice and consent must be obtained before policy issued
  • Reporting: Form 8925 required annually for employer-owned life insurance
  • Exceptions: Death benefit income tax-free only if employee was director, highly compensated, or 5% owner