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Loeb & Loeb’s D.C. Trusts & Estates Practice Leader, Todd Steinberg, is quoted in Tax Notes Federal's recent article “Offshore Life Insurance: Wrapped in Controversy Amid Senate Probe,” providing crucial insights into the complexities of private placement life insurance (PPLI) which have recently come under scrutiny for their legal boundaries.
In the publication, Steinberg underscores the unique nature of each PPLI plan, highlighting the need for meticulous documentation and execution. Steinberg states, "Every structure, every technique is different in how it’s implemented and how it is documented—what i’s are dotted, t’s crossed.” Steinberg adds that, fundamentally, an appropriate investment in a PPLI—certainly not domestically—wouldn’t be a closely held business asset over which the insured has more than a de minimis control or ownership interest.
In the publication, Steinberg underscores the unique nature of each PPLI plan, highlighting the need for meticulous documentation and execution. Steinberg states, "Every structure, every technique is different in how it’s implemented and how it is documented—what i’s are dotted, t’s crossed.” Steinberg adds that, fundamentally, an appropriate investment in a PPLI—certainly not domestically—wouldn’t be a closely held business asset over which the insured has more than a de minimis control or ownership interest.
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D.C. Trusts & Estates Practice Leader