For US persons, an irrevocable life insurance trust (ILIT) is arguably the most efficient structure for integrating tax-free investment growth, wealth transfer and asset protection. An ILIT comprises two main parts: (1) an irrevocable trust; and (2) a life insurance policy owned by the trust. An international (or offshore) ILIT is a trust governed by the law of a foreign jurisdiction that owns foreign-based life insurance. An offshore ILIT is better than a domestic ILIT because it is more flexible and less expensive. Regarding US tax laws, a properly designed international ILIT is treated virtually the same as a domestic ILIT.An ILIT becomes a dynasty trust (or GST trust) when the trust’s settlor (or grantor, the person who establishes and funds the trust) applies his lifetime exemption for the generation skipping transfer tax (GSTT) to trust contributions. Once a dynasty trust is properly funded by applying the settlor’s lifetime exemptions for gift, estate and GST taxes, all distributions to beneficiaries will be free of gift and estate taxes for the duration of the trust, even perpetually. The individual unified gift and estate tax exemption and the GSTT exemption are both $5 million ($10 million for a married couple) during 2011 and 2012, which are the highest amounts in decades.Under the US tax code, no income or capital gains taxes are due on life insurance investment growth, and no income tax is due when policy proceeds are paid to an insurance beneficiary upon death of the insured. When a dynasty trust purchases and owns the life insurance policy and is named as the insurance beneficiary, no estate tax or generation skipping transfer taxes are due. In other words, assets can grow and be enjoyed by trust beneficiaries completely tax-free forever. Depending on how a trust is designed, a portion of trust assets can be invested in a new life insurance policy each generation to continue the cycle.Private placement life insurance (PPLI) is privately negotiated between an insurance carrier and the insurance purchaser (e.g., a dynasty ILIT). Private placement life insurance is also known as variable universal life insurance. The policy funds are invested in a separately managed account, separate from the general funds of the insurance company, and may include stocks, hedge funds, and other high-growth and/or tax-inefficient investment vehicles. Offshore (foreign) private placement life insurance has several advantages over domestic life insurance. In-kind premium payments (e.g., stock shares) are allowed, whereas domestic policies require cash. There are few restrictions on policy investments, while state regulations restrict a domestic policy’s investments. The minimum premium commitment of foreign policies typically is US$1 million. Domestic carriers demand a minimum commitment of $5 million to $20 million. Also, offshore carriers allow policy investments to be managed by an independent investment advisor suggested by the policy owner. Finally, offshore policy costs are lower than domestic costs. An election under IRC § 953(d) by a foreign insurance carrier avoids imposition of US withholding tax on insurance policy income and gains.Whether domestic or offshore, PPLI must satisfy the definition of life insurance according to IRC § 7702 to qualify for the tax benefits. Also, key investment control (IRC § 817(g)) and diversification (IRC § 851(b)) rules must be observed. When policy premiums are paid in over four or five years as provided in IRC § 7702A(b), the policy is a non-MEC policy from which policy loans can be made. If policy loans are not important during the term of the policy, then a single up-front premium payment into a MEC policy is preferable because of tax-free compounding.An offshore ILIT provides much greater protection of trust assets against creditors of both settlor and beneficiaries. Courts in the US have no jurisdiction outside of the US, and enforcement of US court judgments against offshore trust assets is virtually impossible. Although all offshore jurisdictions have laws against fraudulent transfers, they are more limited than in the United States. In any case, an offshore ILIT is necessary to purchase offshore life insurance because foreign life insurance companies are not allowed to market and sell policies directly to US residents. An international trust, however, is a non-resident and is eligible to purchase life insurance from an offshore insurance carrier.An international ILIT may be self-settled, that is, the settlor of the trust may be a beneficiary without exposing trust assets to the settlor’s creditors. In contrast, in the United States, the general rule is that self-settled trusts are not honored for asset protection purposes.In Private Letter Ruling (PLR) 200944002, the IRS ruled that assets in a discretionary asset protection trust were not includable in the grantor’s (settlor’s) gross estate even though the grantor was a beneficiary of the trust. The trustee of a discretionary trust uses his discretion in making distributions to beneficiaries consistent with trust provisions. Previously, it was questionable whether a settlor could be beneficiary of an ILIT without jeopardizing favorable tax treatment upon his death. The new ruling gives some assurance to a US taxpayer who wants to be a beneficiary of a self-settled, irrevocable, discretionary asset-protection trust that is not subject to estate and GST tax. As a result, the trustee can (at the trustee’s discretion) withdraw principal from the PPLI or take a tax-free loan from the policy’s cash value and distribute it tax-free to the settlor, as well as to other beneficiaries. In other words, a settlor need not sacrifice all enjoyment of ILIT benefits in order to achieve preferred tax treatment.An offshore ILIT is designed to qualify under IRS rules as a domestic trust during normal times and as a foreign trust in case of domestic legal threats to its assets. The offshore ILIT is formally governed by the laws of a foreign jurisdiction and has at least one resident foreign trustee there. As a “domestic” trust under IRS rules, the trust also has a domestic trustee who controls the trust during normal times. If a domestic legal threat arises, control of the trust shifts to the foreign trustee, outside the jurisdiction of US courts, and the trust becomes a “foreign” trust for tax purposes. A domestic trust “protector” having negative (or veto) powers may be appointed to provide limited control over trustee decisions. An international ILIT protects trust assets against unforeseen lawsuits, bankruptcy and divorce.The objective of PPLI is to minimize life insurance costs and to maximize investment growth. The life insurance policy acts as a “wrapper” around investments so that they qualify for favorable tax treatment. Nevertheless, PPLI still provides a valuable life insurance benefit in case of an unexpected early death of the insured.Initial costs of setting up an ILIT are high, but are recouped after a few years of tax-free investment growth. Initial legal and accounting fees are typically in a range of $25,000 to $50,000. Premium “loading” charges are in a range of about 3% to 5% of premiums paid into offshore PPLI (compared to 8 – 10% in domestic PPLI). Annually recurring charges depend on policy value and vary widely among PPLI carriers, so careful comparison shopping is advised. For example, annual asset charges should be in a range of about 40 to 150 basis points (0.4% to 1.5%) of the policy’s cash value. The annual cost of insurance is not substantial and declines over time. Annual costs for maintaining an offshore trust are several thousand dollars. Finally, investment manager fees are paid regularly out of policy funds.Cash may be contributed to the ILIT, which then purchases PPLI. If asset protection of vulnerable fixed assets in the US is a concern, then equity stripping can be used to generate cash, which is then contributed to the offshore ILIT. Of course, stocks and bonds and other assets may also be contributed to the ILIT and used for investing in PPLI. Various value-freezing and valuation discounting techniques can be used to leverage the GSTT exemption.An offshore “frozen cash value” policy is a variation of PPLI governed by IRC § 7702(g). The minimum premium commitment is about $250,000. During the life of the insured, the cash surrender value is fixed at the sum of the premiums paid. Withdrawals up to the amount of the paid-in premiums are tax-free, but cash value in excess of the premium amounts is inaccessible until after death of the insured.Another alternative investment for an ILIT is a deferred variable annuity (DVA). There is no cost of insurance, so investment growth is faster. Tax on appreciation is deferred, but DVA distributions are taxed as income.Generally, for public policy reasons and because the insurance industry possesses strong political influence, life insurance has long enjoyed favorable tax treatment. Over the past two decades, numerous IRS rulings have clarified the tax treatment of PPLI and irrevocable discretionary trusts. At the same time, strong, new asset protection laws and reliable service providers in numerous foreign jurisdictions have enabled safe, efficient and flexible management of international trusts and insurance products. As a result, an international irrevocable, discretionary trust owning PPLI can provide tax-free growth of a global, variable investment portfolio managed by a trusted financial adviser in full compliance with US tax laws. At the discretion of the trustee, trust assets (including tax-free insurance policy loans and withdrawals) are available to the settlor during his lifetime. Upon death of the insured, policy proceeds are paid tax-free to the trust. Thus, a well-managed life insurance dynasty trust perpetually secures the financial well being of settlor, spouse, children and their descendants.Warning & Disclaimer: This is not legal advice.Copyright 2011 – Thomas Swenson
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Neo Humanistic Education
According to scientists, the human potential is really unlimited, but up to the level of civilization we now only use only one percent of the potential. If this is so, then the foremost task of education is to remove all potential possessed by every human being for every human being human whole, complete. And this is indeed the task of Neo Humanist Education, which were made in an integrated effort to tap the highest potential in every child, at any time and any place.
Neo Humanist Education provide education to all sections that make up the child, not just memorize information and stuffed to the intellect, or train the child into a robot for teachers to be happy because he would issue the desired answers.
As was said as Neo Humanist Education should be given to children from an early age. That is why Shrii P.R. Sarkar, Neo Humanist Education pioneer with the introduction of the philosophy of Neo Humanism, suggested to establish more kindergarten or Pre-School, which introduced a system Neo humanist education.
Why P.R. Sarkar did not recommend establishing more universities? It is generally recognized as a fact most of one’s development occurs at the age of below 5 or 6 years. At this age period children’s cognitive and personality structure itself which will determine the way of life to the next. Therefore, the teachers and the best facilities should be concentrated on education kindergarten and elementary school.
P.R. Sarkar said that in every person there is thirst for something infinite. One of the most important task of education is to arouse the desire for an unlimited expansion of the (science). That must be generated on each student is feeling, “I want to know or unite.” While the traditional education system is still far from this in such business. Expectations held by each of the children born were more likely to fall apart, as a result of the injustices that occur at this time. Humans began as a butterfly and ends as a cocoon.
It is time the education system is designed in such a way that does not produce people who are only half-knowledgeable, which later developed into the aggressive, confused, dissidents and frustration.
The next result, a series of social networks become increasingly damaged. Viewed as a whole, more and more teenagers who drop out of school, wandering, and lapse into the use of illicit drugs (drugs), destructive environments, exposed to venereal disease, left home, mad or committed suicide.
It’s so much money and time sacrificed to try to fix the education system. But unfortunately, many have failed, because of the attention focused on the wrong source of the problem, namely by increasing the intensity of cramming information. In many countries, reform in education means more hours and teaching materials as well as spend more on information to children who actually already saturated.
Where is busy memorizing this information has reduced the quality and dignity of human beings and destroying the lives of students. When the children viewed as a basket of its main functions to receive, store and pulled back the data and facts, then the learning process that will be mechanistic and bored students who will become aggressive and frustrated or looking for an outlet uncontrolled emotions. We need change, and it must be done now.
We first have to understand what is described by PR Sarkar, and was supported by the principles of modern physics that our presence is not just the fact that visible by the five senses, but is a continuous series of different layers of consciousness, ranging from the coarsest layer of the physical body, continues toward the layers of the ie finer psychic layers, and finally arrive at a unified field with infinite consciousness. The whole psychological layer that can be identified into 5 layers:
1. Keep your awareness (Conscious Mind): SENSING
2. Unconscious (Subconscious Mind): INTELLECT
3. The first layer Supra Consciousness: CREATIVITY
4. The second layer Supra Consciousness: INTUITION
5. The third layer supra Consciousness: SPIRITUAL
Within each of the higher consciousness that there are a wider knowledge which give more happiness, because of the higher layers of a wider scope and contain energy reserves are not playing much.
These layers are not just a theoretical conception of the psychologist, but it is a functioning level that can be experienced by everyone who practiced with great discipline to explore his soul. But unfortunately, in general people are not aware of the most important levels of the innermost soul, and we usually live with the two lower levels of conscious and subconscious layers only.
What makes the Neo Humanist Education is unique, is that the systems and methods of this education is systematically developing all layers of human existence and gradually lead the individual toward a goal that is not limited.
So Neo Humanism Education is indeed an overall education (holistic education), because in the process of education that no part of human consciousness is neglected, no aspect of human life that are not addressed. By understanding the characteristics of human existence as a whole is an educator will be easier to explore teaching methods that are better suited to the psychology students.
Neo-Humanistic Educational Objectives:
* Develop full potential of children: physical, mental, and spiritual.
* Generating thirst for knowledge and love (love) learning.
* Equipping children with academic ability and other skills necessary for further education.
* Facilitating the growth and development of the child’s personality, including morality, integrity, confidence, discipline, and cooperation.
* Developing physical and mental stamina stability through yoga and meditation, exercise and play.
* Develop a sense of aesthetics and appreciation of culture through drama, dance, music and visual art.
* Encouraging children to become active members of society and responsible.
* Increase awareness of ecology in the broadest meaning, namely the awareness of all things affiliated with each other, and promote respect and care for all creatures.
* Increase the view of Universal, free from religious differences, skin color, gender, and so forth.
* Understand the importance of the role of teachers in providing an example.
ASPECTS OF HUMAN PERSONALITY AND METHODS OF EDUCATION NEO HUMANIST
To develop them:
* Body material – development through calisthenics exercises are lightweight and rugged, subtle yoga exercises (yoga asanas), dance, and healthy food.
* Awareness realize its development through sensory-motor activities, including exercises in practical life, a supportive environment, ethics or pro-social activities.
* Awareness subconscious intellectual development through activities and use of sensory-motor games and fantasy (playway method).
* Awareness of the creative development of their own initiative and self-expression through creative art, fantasy games and drama.
* Awareness of intuitive wisdom of a smooth development and universal love through curriculum Circle of Love (Circle of Love) and the use of stories and songs that have universal value.
* Awareness of spiritual development through meditation (quiet-time), story and spiritual songs, and dances a soft yoga.
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