Private Placement Life Insurance: Avoiding Income and Transfer Tax for High Net Worth Taxpayers
Meeting IRS Ownership, Diversification, and Insurance Guidelines

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Thursday, May 12, 2022
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
-
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This webinar will explain private placement life insurance (PPLI), including structuring considerations, asset selection, and meeting IRS requirements for tax practitioners working with high net worth taxpayers.
Faculty

Mr. Warren is an attorney with over 20 years of professional experience practicing law and working in the financial services industry serving the trust and wealth management needs of high and ultra-high net worth families across the nation and around the world. Prior to establishing Bridgeford Trust Company, he was recruited out of a large and prestigious Mid-Atlantic law firm to join the Wealth Management/Trust Department of a regional bank as a Vice President/Senior Trust Administrator. Mr. Warren subsequently transitioned his career to Bank of New York Mellon where he worked exclusively and extensively with high and ultra high net worth families on various wealth management issues including asset protection and legacy planning.

Mr. Foley brings 20+ years of financial services and insurance industry experience. Prior to joining Spearhead, he served as the Senior Vice President of Agency Distribution at Lombard International. Mr. Foley oversaw all agent distribution in the U.S., and personally managed the Alpha Alliance, which is the exclusive membership program at Lombard reserved for professionals and firms with a proven tradition of service to the high-net-worth client community.

Mr. Lipkind, Chair of the firm’s Tax Planning and Controversies Practice, concentrates his practice in the areas of wealth preservation, asset protection, and state and federal income taxation. He is experienced in the laws, regulations and nuances surrounding gift and estate taxation and tax controversies, and he counsels closely held businesses and their owners on optimal tax structures, internal governance, and mergers and acquisitions. Mr. Lipkind is valued for his sensitivity to estate planning issues, counseling corporate entities as well as high-net-worth individuals on asset protection, wealth preservation, asset protection and intergenerational issues.
Description
PPLI allows high net worth individuals and family offices to purchase alternative investments that grow tax-free in insurance dedicated funds (IDFs) and can be distributed tax-free upon the death of the insured. Since earnings on comparable investments held personally would be subject to federal tax at ordinary or capital gains rates and state income tax, individuals residing in states like New York and California can reap tax savings of nearly 50 percent.
Along with tax savings, owners can access the funds tax-free by withdrawing original contributions or borrowing from the policy. PPLIs, however, are subject to stringent IRS guidelines. Insurance standards, diversification, and owner control requirements must be satisfied; otherwise, the policy could be disqualified, resulting in significant tax obligations and penalties.
Listen as our panel of life insurance experts discusses the benefits and caveats of PPLI. Tax advisers working with wealthy clients in high income tax brackets, and particularly those in high taxed states, need to understand PPLIs in order to take advantage of this powerful tax planning tool.
Outline
- PPLI: background
- Benefits
- Income tax
- Transfer tax
- Other
- Caveats
- Structuring considerations
- Asset selection
- Best practices
Benefits
The panel will cover these and other critical issues:
- What restrictions are placed on an investor's interactions with the PPLI?
- Meeting the diversification of asset requirements
- Establishing and funding an IDF
- How does the owner withdraw funds tax-free?
- What steps can be taken to minimize the risk of disqualification?
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Identify taxpayers who would benefit most from PPLI
- Determine the appropriate holding structure for a PPLI policy
- Decide which assets are best for funding PPLI
- Ascertain when an owner's actions could disqualify the policy
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of individual income taxation, including itemized deductions, individual income tax credits, net operating loss limitations including carrybacks and carryforwards.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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