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The Special Purpose Insurance LLC - What the Sophisticated Advisor Needs To Know!



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Special purpose insurance LLCs have become extremely popular over the past 5 years. When utilized in buy-sell planning, their inherent flexibility can solve many of the issues raised cross-purchase and entity redemption arrangements.  However, special purpose insurance LLCs raise a variety of complex legal and tax issues that many advisors may not be fully aware of.

The best way for advisors to get fully up to speed on this important development is to join Michael Geeraerts in his exclusive LISI Webinar where he will address all of the critical planning issues raised by special purpose insurance LLCs. In his webinar, Michael will cover the following issues:

  • What is a special purpose insurance LLC for buy-sell planning and what are its advantages over traditional structures
    • Cross-purchase vs. entity redemption buy-sell arrangements
    • Issues with trusteed cross-purchase arrangements
  • Tax benefits of using an insurance LLC
  • Creditor protection with insurance LLCs
  • Allocation of the life insurance premiums
  • Transfer for value considerations
  • Valuation of the insurance LLC membership interest
  • Using an insurance LLC to hold key employee life insurance
  • Using an insurance LLC as an alternative to nonqualified deferred compensation plans 
     

To register for just the webinar only use the BUY NOW BUTTON ON THIS PAGE.

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CLICK HERE for the webinar and eBook bundle with Limited Time Discount

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CLICK HERE to order the eBook separately with Instant Delivery

 

The Special Purpose Buy-Sell Insurance LLC covers the waterfront on all of the tricky issues advisors need to master, including:

  • Transfer-For-Value issues in light of the final TFV regulations
  • Tax benefits of using a Special Purpose Buy-Sell Insurance LLC
  • Creditor protection with Special Purpose Buy-Sell Insurance LLC
  • Premium payments and allocations among the members
  • Valuing the insurance LLC membership interest upon death

Best of all, this book comes with specimen documents, including a sample operating company buy-sell agreement as well as a sample special purpose buy-sell operating agreement!

Here’s what Bob Keebler says about this book:

The Special Purpose Buy-Sell Insurance LLC, is a must-read resource for anyone helping clients with insurance-funded buy-sell agreements. It not only makes a strong case for using a special purpose LLC, but also provides what you’ll need to put the plan into action. I plan to keep my copy handy.


Here’s a quick look at the Table of Contents:

Introduction

1

Trusteed Cross-Purchase Agreements

3

What is a Special Purpose Buy-Sell Insurance LLC?

7

Transfer-For-Value Final Regulations – Considerations for BSILLC

10

Tax Benefits of Using a Special Purpose Buy-Sell Insurance LLC

20

Creditor Protection with Special Purpose Buy-Sell Insurance LLC

23

LLC Planning Considerations

25

Premium Payments and Allocations Amongst the Members

34

Valuing the Insurance LLC Membership Interest Upon Death

48

The Insurance LLC In Private Letter Ruling 200747002

51

Sample Operating Company Buy-Sell Agreement

55

Sample Special Purpose Buy-Sell Insurance LLC Operating Agreement

68

Appendix

82

Private Letter Ruling 7918022

83

Private Letter Ruling 9349002

85

Private Letter Ruling 9625013

98

Private Letter Ruling 200747002

107

Private Letter Ruling 201217017

117

Rev. Rul. 88-76

123

Rev. Proc. 2005-25

128

Rev. Proc. 2019-3

137

ESTATE OF FRANK H. KNIPP., 25 TC 153

176

ESTATE OF CARTWRIGHT v. COMM., 183 F.3d 1034

196



There will be no CE for this webinar


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Michael Geeraerts, CPA, JD, CGMA®, CLU® is an advanced planning consultant at The Guardian Life Insurance Company of America®. Prior to joining Guardian, Michael was a manager at PricewaterhouseCoopers LLP and a tax consultant at KPMG LLP. Michael’s experiences range from preparing tax returns for middle market companies, auditing billion-dollar mutual funds’ financial statements, to researching unique tax savings strategies for various companies.  Michael has written articles for numerous national publications and has delivered continuing education courses to CPAs and attorneys on a variety of estate, business and income tax planning strategies.



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