A common theme in current tax planning (if there is one) seems to be ensuring substance to the form. A number of countries including Mexico seem to being moving towards the US model in this regard.
Tax planning today, if not tomorrow, without a cogent business rationale, will always be exposed to challenge — successful or otherwise. Mid-Ocean is a strong proponent of international private placement life insurance (particularly in the US, Mexican and Canadian context). It provides both the desired tax result and a cogent economic rational or commercial purpose for the tax planning. Or re-stated, the tax benefit is merely an additional benefit to the client’s principal desire to diversify assets internationally and get insurance coverage in the direct-access/private placement arena at discounted rates.
And from an asset protection standpoint, a trust (US domiciled or otherwise) owning an IRC 7702 tax compliant VUL policy provides perhaps the best protection from unforeseen/would-be creditor as well as mitigating the effort of the one certain/present creditor; the US Treasury. The Bahamas by Statute, like some US States, exempts insurance from the claims of creditor, irrespective of the conveyance period.
Mid-Ocean offers itself as consultant on the acquisition of insurance (to both individuals and institutions) by providing expertise and objectivity and in so doing, real added value.
Added value in the sense that Mid-Ocean sees that policies are properly structured at the outset with the best interests of the client in mind (as opposed to the insurance company) and we provide an ongoing monitoring of such a policy for a reasonable and transparent fee.