We have proudly expanded into the international stage to help global families migrating their wealth, U.S. residents living in other countries, or wealthy foreigners moving to or investing in the U.S.
International Private Client Consulting Services
Pinnacle understands the complexities of cross-border life insurance planning for investing and/or generational wealth transfer. We can help preserve, protect and grow generational wealth. For ultra-affluent families, minimizing income taxes and transfer taxes is a critical component of the overall wealth management puzzle. We work with you at every stage and in every aspect of the insurance process, from planning to execution. Clients and their advisors have a different experience with Pinnacle — from the very start.
Solutions for Foreign Investors
To combat paying punitive U.S. taxes while maintaining financial privacy, Pinnacle can help guide you through a private placement life insurance policy to effectively avoid ECI or FIRPTA for foreign investors. The investment is held in the insurer’s separate account (not subject to general creditor claims) and can be invested in U.S. alternatives. The policy is institutionally priced and privately negotiated, with the primary goal of minimizing fees and maximizing compounding of the underlying asset.
Beneficiaries of Foreign Trusts
U.S. Beneficiaries of Foreign Trusts
Whether cross-border planning for global families or protecting a nest egg for U.S. based clients, foreign trusts offer a broad range of planning opportunities but also potentially draconian tax results for U.S. beneficiaries. A private placement life insurance (PPLI) policy or private placement variable annuity (PPVA) policy provides significant tax benefits to U.S. (or U.S. tax resident) beneficiaries of foreign non-grantor trusts to allow tax-free (or tax-deferred) asset accumulation within the policy and tax-advantaged access to the funds (PPLI only).
Immigrating to the United States
From a U.S. tax and regulatory perspective, global citizens face numerous challenges. For those contemplating a longer U.S. stay, a PPLI policy offers a more permanent solution. A PPVA and/or PPLI solution can be combined with trusts to provide income tax, estate tax and creditor protection benefits for a comprehensive pre-immigration plan. Let Pinnacle help you walk through them and decide what’s best for your situation.
Forced Heirship Laws, Imposition of U.S. Estate Taxes, and Other Considerations
In addition to PPLI, there may be other times when a non-U.S. person may want to acquire a U.S. life insurance policy. In general, the U.S. life insurance market is more price efficient than non-U.S. life insurance products and provides a wider depth of policy options. Such policies may be appealing when equalizing inheritances within countries with forced heirship laws or to offset the imposition of U.S. estate taxes. Pinnacle can assist in the efficient acquisition of U.S.-based life insurance coverage for non-U.S. persons.
This material is intended for informational purposes only and should not be construed as legal or tax advice and is not intended to replace the advice of a qualified attorney or tax advisor.