Private Placement Life Insurance (PPLI) and Insurance Dedicated Funds (IDFs): The Ultimate Tax-Efficient Wrapper for Hedge Funds and Alternative Assets

For the Ultra-High-Net-Worth (UHNW) investor, the greatest erosion of wealth is often not market volatility, but **income taxation**. High-yielding alternative asset classes—such as Hedge Funds, Private Credit, and Distressed Debt—are notoriously tax-inefficient. They generate significant…

The Mechanics of Intergenerational Split-Dollar Life Insurance: Discount Valuation, Loan Regime Taxation, and the Morrissette/Cahill Legal Landscape

In the rarefied air of ultra-high-net-worth estate planning, **Intergenerational Split-Dollar (IGSD)** life insurance stands as a formidable, albeit highly scrutinized, strategy. Unlike traditional corporate split-dollar plans designed for executive compensation, IGSD is purely an estate…