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Estate Planning for High-Net-Worth Individuals
In addition to anyone, more specically for high Net Worth Individuals ...
Depending on the value of one’s estate
upon death, the estate may be subject to both Federal
and State estate taxes. Life insurance can be an ideal
source of liquidity for the estate to cover these taxes.
However, to satisfy this objective the affluent individual
is typically not the owner of a life insurance policy
insuring their own life. This would result in the death
benefit being part of the estate for estate tax purposes
thereby increasing the overall estate tax liability
There are numerous life insurance ownership strategies
that avoid this outcome. One of the most commonly
used strategies involves the affluent individual
establishing an irrevocable life insurance trust (“ILIT”)
to be the owner and beneficiary of the policy. Upon
the insured’s death, the life insurance death benefit
paid to the ILIT may be used to provide the estate with
liquidity through the trustee either 1) lending money to
the insured’s estate; or 2) purchasing assets from the
insured’s estate. With proper drafting and execution,
such transactions between the ILIT and the insured’s
estate should not cause the death benefit to be added to
the insured’s estate for the purposes of calculating the
estate tax
Of Significance
The 2017 Tax Cuts and Jobs Act doubled the gift and
estate tax exemption amount starting in 2018, which has
been adjusted for inflation in the subsequent years. This
higher exemption amount is set to sunset on December
31, 2025. On January 1, 2026, the exemption amount
will revert to the pre-2018 amount of $5 million base per
person ($10 million base for married filing jointly), as
adjusted for inflation.




