Business Risk I nsurance Via Sm all Captive I nsurance Cos. Schem atics
Presented By:
Tom King
Proprietary Property
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,
Proprietary Property
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
authorized to make such disclosure include all parties thereto.
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
without the illustration of contract values and the accompanying supplemental footnote
accompany this proposal.
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
Proprietary Property
( 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
Proprietary Property
Family Member (s), Unrelated Party, Back to CIC
Proprietary Property
( 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
Proprietary Property
( 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
reduced Value Preferred Mem bership I nterests Shares
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
Proprietary Property
( 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
Receives all PaLLC assets upon the death
Tax-Free
Cash Flow Assets at
Business
death
Preferred
Owner
Common
Owner