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
Special Training For Brain Development Of Kids
Many researchers have proven the fact that functioning of brain cells of infants is twice active as adult’s brain. Neurons are the brain cells that connect together and power of neuron have the potential of a PC. Connectivity of neurons decides the smartness or intelligence of individuals. In human, brain development and the learning ability of an individual is 50% in the first four years of age. The nerves of individuals are reduced as they grow up and this is why the 1000 trillion nerves present in an 8 months baby are reduced to 500 trillion as it grows up. A child that has given more opportunities to explore will be much smart.
A majority of children, more than 90% of them use their left brain, but the imperative fact to remember is the right brain must also be utilized. Education system present in almost all the schools is designed to develop or use the left brain. Right brain is never the less significant because it is responsible for creativity, arts, feeling, imagination, visualizing, daydreaming, rhythm, holistic thinking and many others. Hence it is equally important to develop both side of brain. It is also most important to take steps to keep both the brain much active, by keeping them to perform analytically on an equal basis. It is the responsibility of parents to give activities to their children that ensures the involvement of both brain. If both brain used by children it is probable to enhance their learning power and they can also increase their brain power. If brain development programs are offered to children they can make most of the program and develop their skills to give work to both side of brain and remains high in intelligence level. Development of brain in human beings is based on the degree of how much it is used. If it is left unused there are more probabilities for individuals to lose as brain works on the basis of use it or lose it.
To ensure the progressive brain development in children, it is the role of parents to introduce their children with a reputable brain development program. Most of the experts suggest step by step educational program to the children which is systemic and efficient. Nowadays it is very simple to find out a lot of schools which not only gives importance to academic program, but they also boost the creativity of children through their extracurricular activities. It is probable to search internet and get hold of relevant schools that present with a variety of activities to stimulate the brain and encourage the development of children. A total development program to stimulate mental activity of children is also found out in the online sites and parents can try out these activities with their children while they are at home. Getting education from a school that implements total development program is much beneficial. Search for such schools and secure admission to enhance the future of the children and boosts in brain development.
Effective Delegation – Management Skills For Plateau Protection
Let’s face it, these are difficult economic times in the job market and for getting promoted within your organization. Budgets are tight. There are hiring freezes and lay-offs. Advancement within your organization seems a distant possibility. For those that are getting laid off, this is a terrible time.So what are you doing about it?The most important thing in any of these tough circumstances will be to pay attention to your management skills. Among the most important of these will be effective delegation and people management. A serious effort to improve your skills and effectiveness will reduce the chance of losing your ground and increase your chances for advancement. Companies and businesses seek results, now more than ever. Take a close look at what the organizations needs are for their management teams.
Ability to execute. Managers are charged with getting things accomplished through others. Leading and managing a team to execute assignments and projects. This has not changed. Most managers do not focus on their management skill improvement in this critical area.
Team building skills. A manager who excels at building a stronger more capable business unit will always be sought after and rise to the top. A candid assessment of the manager’s interpersonal skills such as communication and relationship building id needed in all situations.
Project management skills. The ability to plan and execute projects and assignments is a core competency. Yet managers spend so little time thinking about how to get better at planning the work they are managing. Putting effective project action plans together, even for basic team assignments, really boosts execution and results.
Managers and leaders can not stand still and continue to assume they have these important areas down pat. That kind of “head in the sand” approach can derail a career for sure. What makes a great manager? Taking action and getting things executed. So, why not take action on paying attention to your own development and focusing on continuous management skill development? This starts with making periodic assessments of your skills and setting new professional development objectives. Here, are three things any manager can do to set themselves on a positive course.
Take some time to complete a “self-assessment” of your management skills. Being totally candid, what areas are you falling short in related to getting business unit results? Ask yourself, “if I were a senior manager, looking at my progress and the results of my business unit, what constructive suggestions would be made?
Seek feedback from key members of your team or peers in the organization. The strongest managers seek and accept constructive feedback. Everyone has one or more “management blind-spots.” Things you can not see clearly about your-self, your skills and your performance. Don’t be blind-sided by your blind-spots. Have the courage and maturity to ask how you can get better.
Learn to delegate effectively. It is a premier skill for top performers. Most managers are really rather average at delegating work effectively, but most think they are good at it. You can learn more about the management skills for effective delegation and improve upon them quickly. They are at the heart of superior execution and building high-performance business units.
The benefits of paying attention to your professional skills are worth every effort. Upper management will start to see your focus and dedication. The effectiveness of your team’s ability to execute will increase and will be noticed. If you are seeking a new position, the time and effort you can demonstrate you have invested in your own development will separate you from the competition. Your business unit will feel the positive effects of your skill development and be will be motivated to perform at higher levels. If you were hiring someone or considering a manager for advancement, wouldn’t you take notice of the consistent self-development efforts and increase in skill? Of course, you would and that’s why you must take action to get better.