wealth transfer planning using private financing prepared for valued client & valued client a...

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Wealth Transfer Planning Using Private Financing Prepared for Valued Client & Valued Client A Fair Market Loan Arrangement Between Family Members

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Wealth Transfer Planning

Using Private Financing

Prepared for

Valued Client & Valued Client

A Fair Market Loan Arrangement Between Family Members

The Concern

• Your estate will be subject to estate tax at death.

• Gifts of large premiums to a trust may be subject to gift tax.

The Solution

• Establish fair market loan arrangement between you and an ILIT.

• Make gifts of annual loan interest only, or defer interest.

• Repay loan at death from life insurance, or during lifetime from other funds.

Trusts should be drafted by an attorney familiar with such matters in order to take into account income and estate tax laws (including the generation-skipping tax). Failure to do so could result in adverse tax treatment of trust proceeds.

How It Works

• Your trust borrows the funds to pay premiums from you.

• You can lend the amount needed annually, or lend an amount based on a schedule of premiums or a lump sum amount.

• You make annual premium gifts to the trust to cover loan interest payments, if any.

How It Works

Net To The HeirsNet To The Heirs$7,403,116$7,403,116

The Client The Client FamilyFamily

Outstanding Loan inYr. 30$3,243,338

Total Loan to ILIT = $1,700,140

Total Premiums$2,501,895

Life Insurance Life Insurance Death BenefitDeath Benefit

$9,257,379$9,257,379

ILITILIT

Note & Loan Interest Payments

Death Benefit in Yr. 15$9,257,379

Total Side Fund in ILIT in Yr. 15$0

Total Trust Total Trust Assets Assets in Yr. 15in Yr. 15

$10,646,454$10,646,454

Death Benefit in Yr. 15$7,403,116

Total Gifts to ILIT = $660,000

Components of Premium Financing

• Types of loans

• Loan interest rate

• Loan repayment

• Return of Premium

Comparison of Benefits

Private FinancingPrivate Financing

Total Loan AmountTotal Loan Amount $1,700,140$1,700,140

Cumulative Loan InterestCumulative Loan Interest $1,543,198$1,543,198

Total Gift AmountTotal Gift Amount $660,000$660,000

Total Gift TaxesTotal Gift Taxes $0$0

Total PremiumsTotal Premiums $2,501,895$2,501,895

Total EstateTotal Estate $38,700,858$38,700,858

Total Estate TaxesTotal Estate Taxes $20,389,672$20,389,672

Total Other Assets In TrustTotal Other Assets In Trust -$1,854,262-$1,854,262

Total Death Benefit In TrustTotal Death Benefit In Trust $9,257,379$9,257,379

Net To HeirsNet To Heirs $25,714,302$25,714,302

Benefits

• Minimal or no gift tax

• Heirs receive loan repayment

• Minimal risk

• No income tax on loan interest payment with “Grantor Trust”.

Considerations

• Non-deductible loan interest.

• Possible estate tax cost.

• Potential income tax cost if family entity makes loan.

• Cash flow/liquidity required.

This communication with the public is considered 'Correspondence'. It is authorized for use exclusively for one-on-one use only between and Valued Client & Valued Client. The purpose of this PowerPoint presentation is to act as a tool to help facilitate a discussion between Valued Client & Valued Client, and . Discussion between and Valued Client & Valued Client will generally be extemporaneous in nature and the purpose of the slides is to provide a visual summary for the client of the assumptions and data provided by the client. This tool may be helpful to Valued Client & Valued Client when considering planning options. Not all techniques will be based on estate planning.

Disclaimer