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Kirk Loury - The PPLI Solution: Delivering Wealth Accumulation, Tax Efficiency, and Asset Protection Through Private Placement Life Insurance

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Private placement life insurance (PPLI) was once the exclusive domain of wealthy investors willing to tackle the logistical challenges of the offshore insurance market. The investment portfolio, tax, and estate-planning applications, and ongoing investment potential of these policies made the effort worthwhile. In recent years, though, a number of U.S.-based insurance companies have developed similar policies that meet all U.S. insurance, investment, and tax regulations.

PPLI is becoming a fundamental component of effective tax, trust, and estate planning, but few sources have been available to detail the best practicesuntil now. The PPLI Solution can serve as a resource for effective execution. Written by leading practitioners, the book will position advisers to capitalize as PPLI expands further into the high-net-worth market and becomes available to individuals with an investable net worth as low as $1 million.

Few investorswhatever their net worthwill want to venture into the PPLI market without guidance. The PPLI Solution addresses the needs of investment managers, consultants, attorneys, and accountants who want to achieve the broad understanding of PPLIs applications required of those providing advice. It can serve as an authoritative source for anyoneincluding investorsseeking to know more about PPLIs nearly perfect tax efficiency, solid creditor protection, and powerful means of creating wealth.

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Table of Contents PRAISE FOR THE PPLI SOLUTION Delivering Wealth - photo 1
Table of Contents

PRAISE FOR
THE PPLI SOLUTION: Delivering Wealth Accumulation, Tax Efficiency, and Asset Protection Through Private Placement Life Insurance
Edited by Kirk Loury

All serious practitioners should take the time to readThe Investment Think Tank. Harold Evensky and Deena Katz have done it again with a book covering topics important to our industry and critical to our clients financial success.
CHARLIE HAINES, M.BA, CFP
President and CEO, Charles D. Haines, LLC
ALSO AVAILABLE FROM BLOOMBERG PRESS

Family WealthKeeping It in the Family:
How Family Members and Their Advisers
Preserve Human, Intellectual, and
Financial Assets for Generations
by James E. Hughes Jr.

Creating a Private Foundation:
The Essential Guide for Donors and Their Advisers
by Roger D. Silk and James W. Lintott

The Investment Think Tank:
Theory, Strategy, and Practice for Advisers
edited by Harold Evensky and Deena B. Katz

Hedge Funds Risk Fundamentals:
Solving the Risk Management and
Transparency Challenge
by Richard Horwitz

A complete list of our titles is available at
www.bloomberg.com/books
ATTENTION CORPORATIONS
THIS BOOK IS AVAILABLE for bulk purchase at special discounts. Special editions or chapter reprints can also be customized to specifications. For information, please e-mail Bloomberg Press, press@bloomberg.com, Attention: Director of Special Markets, or phone 609-279-4600.
To my wife Brenda whose faith inspires me and whose support fuels me PREFACE - photo 2
To my wife, Brenda, whose faith inspires me and whose support fuels me
PREFACE
IS IT ANY SURPRISE that a product weighed down with a moniker like private placement variable universal life (PPVUL)otherwise known as private placement variable life insurance (PPVLI) and private placement life insurance (PPLI)has yet to be embraced by wealth advisers? Of course, a snappy name hardly ensures that a product will be considered a vital investment tool, but PPLIs forbidding handle certainly mirrors the complexities that have plagued this investment from its earliest days.
Since 2000, however, the affluent markets need for more sophisticated tax-management, wealth-transfer planning, and asset-protection solutions has converged with an unprecedented demand for alternative investments. It is at this juncture that PPLI stands tall as a maturing, flexible platform able to address an array of complex needs cost-effectively.
Given the dramatic advancements in policy structure and investment options as well as validation by the Internal Revenue Service, its now clear that the time and effort an adviser expends to learn about PPLIs applications will be fruitful. Toward that end, this book has a simple purpose: to be a reference and guidebook for any wealth adviser seeking the knowledge required to identify and articulate the difference PPLI can make in executing a wealth-management plan.
The contributors gathered here to share that knowledge offer not only their skills and understanding but their collective experience as well. This experience is born from the tough and grinding work of pioneers who have pursued PPLI with a fundamental belief that this platform holds great promise in its capacity to deliver the kind of value sought by sophisticated investors and their advisory teams. Indeed, the current policy designs arose as a result of the efforts to minimize unnecessary impediments to effective execution, and the insights reflected in each chapter were gained from handling tough questions and demanding situations. Now the entire wealth-management industry can benefit from the answers, because these pioneering efforts have culminated in a product thats ready for the challenging task of simultaneously preserving and growing wealth.
Each contributor integrates the needed grounding on terminology, concepts, and approaches so that each chapterwhether its about tax deferral or policy structure or legal compliancecan convey an understanding of PPLI thats accessible even to the novice. The book speaks frankly about past misconceptions, missteps, and misgivings that early adopters have had to overcome. To be sure, each contributor is a proponent of PPLI and its status as a powerful investment tool; nevertheless, important best practice boundaries are identified to prevent avoidable failure. PPLI may not fit into every wealth-management plan, but the benefits it can deliver are so substantial and have such broad applications that its clearly worth the trouble to find out if it does. These contributors believeas do Ithat PPLI will add substantially to the plans overall effectiveness.
Acknowledgments
I would like to acknowledge my colleagues at Spencer Trask, particularly our chairman, Kevin Kimberlin, all of whom have been tremendous supporters, giving me the freedom to help lead the charge in bringing PPLI into its own as a core wealth-planning tool. Next, it would be difficult to find another industry so widely populated with the kind of professionals Ive found in PPLI. Not only are they sophisticated thinkers motivated by a drive to serve the client; theyre also willing to help neophytes achieve the understanding needed to be successful. The contributors herein exemplify the personal and professional characteristics that make involvement in the PPLI industry so rewarding.
ABOUT THE CONTRIBUTORS
Paul F. Berlin, CLU, is president of Executive Planning, a Chicago firm that specializes in sophisticated uses of life insurance, and he has more than 22 years of experience in the life insurance industry. In 2001, Berlin developed the product chassisan intellectual property he later sold to MONYthats now used by hedge fund managers as well as banks in the private placement market. Over the years, he has been featured in numerous trade journals, including a February 1992 article in Life Association News titled Ten Future Legends, which predicted that Berlins expertise would eventually make him a legend in the industry. Berlin earned his BS degree in finance from Indiana University and his chartered life underwriter degree from the American College. Berlin may be contacted at exec.planning@prodigy.net; the firms website address is www.executiveplanning.com.

Jeffrey S. Bortnick, Esq., is a tax partner of the general practice law firm of Kleinberg, Kaplan, Wolff & Cohen, in New York, and has more than 22 years of experience in a broad range of tax and estates matters. Bortnick frequently advises hedge funds, private-equity funds, and fund managers on tax issues related to fund formation, operations, and investments. He has written articles for industry publications and lectured on many tax issues related to hedge fund and private placement variable insurance. Bortnick earned his JD and LLM degrees in taxation from NYU School of Law and is a member of the Association of the Bar of the City of New York. He may be contacted at JBortnick@kkwc.com.

Richard Brindisi is an expert in the field of private placement life insurance and other structured insurance programs for wealthy individuals. He was the managing director of marketing for the private placement group at Sun Life Financial before leaving to pursue other interests in the insurance and wealth-management industries. Brindisi has been involved in all aspects of putting together privately placed insurance and annuity contracts for wealthy investors and institutions. Before joining Sun Life, Brindisi was a trust officer at Raymond James Trust and later a senior tax and estate-planning consultant for Raymond James Financial, where he built the private placement insurance program in his role as a consultant to financial advisers for their high-net-worth clients. Brindisi is a graduate of the T.C. Williams School of Law at the University of Richmond.
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