Tom King Proprietary Property Disclosure CIC Services, LLC - - PowerPoint PPT Presentation

tom king
SMART_READER_LITE
LIVE PREVIEW

Tom King Proprietary Property Disclosure CIC Services, LLC - - PowerPoint PPT Presentation

Business Risk I nsurance Via Sm all Captive I nsurance Cos. Schem atics Presented By: Tom King Proprietary Property Disclosure CIC Services, LLC hereby expressly authorizes each person to whom these materials are given by CIC Services,


slide-1
SLIDE 1

Business Risk I nsurance Via Sm all Captive I nsurance Cos. Schem atics

Presented By:

Tom King

Proprietary Property

slide-2
SLIDE 2

Disclosure

  • CIC Services, LLC hereby expressly authorizes each person to whom these materials are

given by CIC Services, LLC or its affiliates or authorized agents (and each employee, representative or other agent of such person) to disclose to any and all persons, without limitation of any kind, the tax treatment and tax structure of the transaction described herein, or effected hereby, and all materials of any kind (including all opinions or other tax analyses) that are provided to such person related to such tax treatment and tax

  • structure. In the case of a document which is a contract or agreement, the persons

authorized to make such disclosure include all parties thereto.

  • Neither CIC Services, LLC nor any person who provided this material to you render legal,

insurance regulatory or tax advice. Your advisors should be consulted for their interpretations of legal, insurance regulatory or tax considerations. Any projections provided reflect current conditions and will likely change in the future. Any illustrations provided are an illustration of values and benefits only and is not to be construed as a

  • contract. To the extent that insurance products are illustrated, this proposal is invalid

without the illustration of contract values and the accompanying supplemental footnote

  • pages. To the extent that investment products are illustrated a current prospectus must

accompany this proposal.

  • “CIRCULAR 230 DISCLOSURE: IN COMPLIANCE WITH TREASURY DEPARTMENT

REQUIREMENTS, WE INFORM YOU THAT ANY FEDERAL TAX ADVICE CONTAINED IN THIS COMMUNICATION AND ANY ASSOCIATED ATTACHMENT IS NOT INTENDED, AND CANNOT BE USED, FOR THE PURPOSE OF (A) AVOIDING PENALTIES UNDER THE INTERNAL REVENUE CODE OR (B) PROMOTING, MARKETING OR RECOMMENDING TO ANY OTHER PARTY ANY TRANSACTION OR MATTER SET FORTH HEREIN.”

Proprietary Property

slide-3
SLIDE 3

Important!

  • The presumption for all of the following slides is that the

client has substantial non-tax insurance needs such that a captive insurance company is needed by the client without regard to any potential tax benefits or other ancillary benefits.

  • Some of the slides that follow only demonstrate the

potential ancillary benefits of a captive insurance company that has been formed for substantial non-tax casualty, loss and liability purposes.

Proprietary Property

slide-4
SLIDE 4

Captive Insurance Company (CIC) Schematic

( 1 ) Business

Can Pay Tax Deductible Ins Premium up to $1.2 Mil Per Year Tax savings= $ 6 0 0 ,0 0 0

( 2 ) CI C

0% Tax Bracket on premiums up to $ 1 .2 Million per year

( 4 ) SM LLC

Single Mem ber LLC

SM LLC is wholly owned by (2) CIC holding all membership interest Upon the death of the Business Owner, all assets will move to the CIC upon which time Family Trust can liquidate its share of the CIC to obtain the cash/ assets from (2.1) Family Trust

( 4 .1 )

Hedging Using Investment Grade Index Life with death Benefit

Investments with Hedging

( 4 .1 )

Investment in Market Equities with limited risk

Premium P&C policies Initial Capital CIC Stock CIC Profits CIC can recall assets to pay claims, etc. Premium Retransfer

( 2 .1 ) Fam ily Trust

Owns all the stock of (2) CIC. Benefits Family only after Business Owner’s Death

( 3 ) Capstone Reinsurance Com pany

Capstone receives 51% of (2) CIC premiums Reinsures 51% of claims made by (1) Business and 51% all other CICs in the risk pool. Capstone retransfers all premiums received back to participating (2)CIC over the year less any claims/ expenses In Exchange for Property & Casualty Insurance policies CIC Own 100% of SM LLC Profits are invested in (4) SM LLC

slide-5
SLIDE 5

Proprietary Property

Exit Strategies Future Exit Strategies To Consider

  • 1. Owner can transfer by gift or bequest to family Member (s)
  • 2. Owner Can Sell Ownership Interest to:

Family Member (s), Unrelated Party, Back to CIC

  • 3. Merge with Another CIC
  • 4. Liquidate the CIC
  • 5. Exist Indefinitely
  • 6. Invest into a Preferred Allocation Limited Liability Company
slide-6
SLIDE 6

Proprietary Property

Captive Insurance Company (CIC) Transition Schematic

( 4 ) SM LLC

(2) SMLLC is wholly owned by CIC holding all membership interest

( 5 ) PaLLC

Preferred Allocation LLC (2) CIC - 95% Preferred Membership Interests with no distribution Rights, is guarenteed return of investment plus preferred return at (7) Business Owner’s death Business Owner - 95% Common Controlling Membership Rights,100% Voting Rights including Distribution

( 7 ) Business Ow ner

Invests 5% of LLC asset value. Receives 95% of the Common Member Rights, 100% Voting Rights

I nvestm ents w ith Hedging

SMLLC Converted to PaLLC w ith CI C Contributing Assets to PaLLC

( 5 .1 )

Investment Life Insurance Policy with Limited Risk Tax Deferred Grow th

( 5 .1 )

Investments in Market Equities with Limited Risk Yearly Tax on Capital Gains and I ncom e

( 2 .1 ) Fam ily Trust

Owns 100% of CIC stock

( 2 ) CI C

Owns 100% of (4) SMLLC

Ow ns

slide-7
SLIDE 7

Proprietary Property

Captive Insurance Company (CIC) Transition Schematic

( 2 ) CI C Prem ium s Stop & CI C is Liquidated ( 5 ) PaLLC

Ownership of Preferred Membership Interests change from CIC to Family Trust. Family Trust Assets will be taxed as capital gains on the value of assets. Value of assets are reduced due to Future Value, Access and Marketability Issues

(6)

I RS Federal Governm ent

( 5 .1 )

Investments in Market Equities with Limited Risk Yearly Tax on Capital Gains and I ncom e

Capital Gain Tax

  • n LLC

reduced Value Preferred Mem bership I nterests Shares

  • f Stock

I nvestm ents

( 2 .1 ) Fam ily Trust

Transfers all CIC stock back to CIC in exchange for Preferred membership interest and the SM LLC Obligation

( 5 .1 )

Investment Life Insurance Policy with Limited Risk Tax Deferred Grow th

slide-8
SLIDE 8

Proprietary Property

Captive Insurance Company (CIC) Exit Strategy Schematic

( 5 ) PaLLC

Preferred Allocation LLC Family Trust - 95% preferred Membership Interests with no distribution Rights Business Owner - 95% Common Membership Interests with Distribution Rights

(7 ) Business Ow ner

Cash Flow

Distributions

( 5 .1 )

I nvestm ent Life I nsurance Policy w ith Lim ited Risk Tax Deferred Grow th PaLLC borrows cash against life insurance death benefit Non-Taxable Loans Non-recourse debt to LLC allows special allocation of basis to Common Member in LLC equal to Loan. Tax Free Death Benefit Replenishes LLC’s Negative Capital Account

( 5 .1 )

I nvestm ents in Market Equities w ith Lim ited Risk Yearly Tax on Capital Gains and I ncom e

( 2 .1 ) Fam ily Trust

Owns 95% Preferred Membership Interests

  • f PaLLC

Receives all PaLLC assets upon the death

  • f the Business Owner

Tax-Free

Cash Flow Assets at

Business

  • wners

death

Preferred

Owner

Common

Owner