Company-owned life on a critical exec — cash value grows tax-deferred, death benefit tax-free.
Company buys life insurance on a key executive (owner, top salesperson, CTO) — premiums non-deductible, but death benefit and cash value grow tax-free (§101(j) notice/consent required to preserve tax-free death benefit). Provides continuity capital if key person dies. Can double as executive-bonus §162 plan or SERP funding.
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Overfund whole life, borrow against cash value at 5–6%, arbitrage into real estate.
Overfund IUL to MEC line — tax-free retirement income via policy loans.
Business pays premium, executive gets death benefit — pennies on the dollar of tax exposure.
Wrap hedge funds/PE inside a tax-free life policy — no LTCG, no ordinary income.
Borrow at SOFR+1.5% to pay life insurance premiums, arbitrage against policy crediting.
Business pays deductible premiums to owner-controlled captive — up to $2.85M/yr tax-free receipts.
Layer umbrella and excess policies for $5M–$50M liability coverage at $500–$5K/yr.
Take higher deductibles on rarely-claimed policies; pocket the premium savings.