Presented by: Life Insurance Planning in a Low Interest Rate Environment Grantor-Retained Annuity...
-
Upload
collin-flowers -
Category
Documents
-
view
215 -
download
0
Transcript of Presented by: Life Insurance Planning in a Low Interest Rate Environment Grantor-Retained Annuity...
NOT INSURED BY FDIC OR ANYFEDERAL GOVERNMENT AGENCY
MAY LOSEVALUE
NOT A DEPOSIT OF OR GUARANTEEDBY ANY BANK OR ANY BANK AFFILIATE
FDIC BANK
INSURANCE PRODUCTS:
NOT INSURED BY FDIC OR ANYFEDERAL GOVERNMENT AGENCY
MAY LOSEVALUE
NOT A DEPOSIT OF OR GUARANTEEDBY ANY BANK OR ANY BANK AFFILIATE
FDIC BANK
INSURANCE PRODUCTS:
Presented by:
Life Insurance Planning in a Low Interest Rate Environment
Grantor-Retained Annuity Trust
0259907-00001-00 Ed. 04/2014 Exp.10/07/2015
Introduction
• Why are interest rates so low?• What may cause rates to rise?• How can low rates help with HNW planning?
• Economy is in recovery mode
• Low interest rates => households, businesses spend, invest more
• More spending, investing => employment growth, rising GDP
Why low interest rates?
The Recovery Cycle – At a Glance
Low Fed Rates
Low Lending Rates
Spending, Investment
Employment, GDP
Consumer, Investor
ConfidenceRecovery
New Demand for Goods, Services
• The Good: Increased consumer, investor demand for credit vs. limited lending capital
• The Bad: Rising inflation
• The Ugly: U.S. debt ratings downgrade
Why could rates rise?
Long-Term Growth – At a Glance
Fed Relaxes Target
Low Fed Rates
Low Lending Rates
Recovery: Sustained
Demand for Credit
Rising Treasury
Yields
Treasury yields determine the AFR (borrowing) and § 7520 (discounting) rates for individual taxpayers
Impact of Rising Treasury Yields
Treasury Yields
AFR § 7520
The Planning Benefits of Low Rates
• Lower interest rates make some wealth transfer strategies more efficient:
– Interest-only borrowing
– Sale of property where buyer has limited ability to pay
– Valuing a donor’s retained interest in property
9
Profile – Grantor Retained Annuity Trust
• Works in low rate environment because:– A low discount rate makes it easier for assets to achieve gains
that can be transferred to beneficiaries gift and estate tax-free
• For individual clients who… Own large income producing and/or highly
appreciated/appreciating assets Would like to pass future income and appreciation to the next
generation without making large gifts Have a current life insurance need
GRATs…Overview
• An Irrevocable Trust• Grantor Retains A Right To Payment of a
Fixed Amount from the trust for a Fixed Period Of Years
• At The End of the GRAT Period, The Remaining Value Passes to a Non-Charitable Beneficiary (such as a trust or a child)
• General Rule: A shorter term is more desirable than a longer term
GRATs….Overview
• Allow Large Transfers of Property With Little or No Gift Tax Cost WHY?
• Because of The Gift Formula: FMV Of Property Contributed – Value of Retained Interest = Taxable Gift
• Discount Rate Uses IRC §7520 Rate in effect when the GRAT is created
• Estate Tax Advantages
GRATs….Overview
• What Types of Property Are Suitable For A GRAT?– Virtually Any Type – Special Rules For Personal
Residences– High Yielding And/Or Expected to Appreciate
Substantially Are Ideal– FLPs: Even Better Gift Tax Leverage If FLP
Interests Are Transferred To A GRAT
The Sleeper GRAT
Question:• What if a client doesn’t have the right assets to fund a
GRAT today, but wants to lock in today’s low 7520 rate?
Answer:• The Sleeper GRAT:
– Locks in the right to value income at today’s rates, until a time when the GRAT strategy is truly appropriate
– “Stores” fixed income assets while returning 100% of their value to the grantor
The Sleeper GRAT
Question:• You said if the 7520 Rate goes up, that’s because Treasury
yields have risen. If that’s the case, won’t investment returns in general also go up, and be adequate to “clear” whatever discount hurdle is then in effect?
Answer:• Not for all clients. Those with long term fixed assets giving
income at today’s relatively modest rates won’t see their returns “float” with the interest rate tide.
• Locking in a rate today might benefit these clients by letting them participate in a low-discount GRAT strategy now, and buy them time to re-tool the rest of their portfolio should rates rise.
The Sleeper GRAT
• The concept: create and fund one or a series of GRATs today (say, 4, 6, 8, and 10 year terms), and fund them with fixed income assets
• The fixed income assets earn the same or slightly more than the hurdle rate – a.k.a. the 7520 rate
• The GRAT is therefore scheduled to return all of the grantor’s asset to him/her over the term, with a zero remainder, unless and until …
The Sleeper GRAT
• § 7520 rate rises significantly, OR• Short-term GRATs are eliminated due to tax law
changes, OR• Grantor acquires an asset that has higher appreciation
potential.
THEN:• One or more of the GRATs could be “switched on” by
swapping volatile assets of equal value (with high appreciation potential) into the GRAT
• Net effect: a short-term GRAT (remaining term) pegged at today’s 7520 rate
The Sleeper GRAT - Examples
– Assume the client has an asset worth $3,094,430 currently earning fixed interest at a rate of 2.2% per year
– The client is interested in the short-term GRAT idea with de minimus gifting consequences
– At the current 7520 rate of 2.2%*, is the client in a good position to fund a GRAT?
– The following slide should provide the answer ..
*March 2014
The Sleeper GRAT - Examples
Year Start Value2.2%
Annual Income
Annuity Balance
1 $3,094,430 $68,077 ($1,077,185 ) $2,085,322
2 $ 2,085,322 $45,877 ($1,077,185 ) $1,054,015
3 $ 1,054,015 $23,188 ($ 1,077,185) $17.84
Short-Term GRAT (Gift = $0)Uses 2.2% 7520 Discount Rate, 2.2% Annual Income from Assets
Switching on the Sleeper GRAT
To preserve the ability to have the three-year GRAT we just saw eight years from now, and use today’s rate of 2.2%:
Fund a 10-year sleeper GRAT now with the $3,094,430 asset, which would produce the values on the following slide.
Switching on the Sleeper GRAT
Year Start Value 2.2% Annual Income Annuity Balance
1 $3,094,430 $68,077 ($348,107) $2,814,400
2 $2,814,400 $61,917 ($348,107) $2,528,210
3 $2,528,210 $55,621 ($348,107) $2,235,724
4 $2,235,724 $49,186 ($348,107) $1,936,802
5 $1,936,802 $42,610 ($348,107) $1,631,306
6 $ 1,631,306 $35,889 ($348,107) $1,319,087
7 $1,319,087 $29,020 ($348,107) $1,000,000
8 $1,000,000 $22,000 ($348,107) $673,893
9 $673,893 $14,826 ($348,107) $340,612
10 $340,612 $7,493 ($348,107) $0
10 Year GRAT (Gift = $0)Uses 2.2% 7520 Discount Rate, 2.2% Annual Income from Assets
Switching on the Sleeper GRAT
Year Start Value Annual Income Annuity Balance
1 $3,094,430 $68,077 ($348,107) $2,814,400
2 $2,814,400 $61,917 ($348,107) $2,528,210
3 $2,528,210 $55,621 ($348,107) $2,235,724
4 $2,235,724 $49,186 ($348,107) $1,936,802
5 $1,936,802 $42,610 ($348,107) $1,631,306
6 $ 1,631,306 $35,889 ($348,107) $1,319,087
7 $1,319,087 $29,020 ($348,107) $1,000,000
8 $1,000,000 $200,000 ($348,107) $851,893
9 $851,893 $170,379 ($348,107) $674,165
10 $ 674,165 $134,833 ($348,107) $460,891
10 Year GRAT (Gift = $0)Uses 2.2% 7520 Discount Rate, 20% Annual Income Years 8-10
Why Life Insurance?
Why Life Insurance?– Counters risk of the client dying during the term of the GRAT– Provides estate liquidity – the GRAT only removes the appreciation
from the estate, not the original asset value, which is paid back via the annuity:• A GRAT is an estate freeze, not an estate reducer
– An ILIT can be the remainder beneficiary of a GRAT– Grantor can allocate GSTT exemption amounts to an ILIT, but not to
a GRAT
Large Case Sales Idea
• Fund large premiums under a Family Split Dollar agreement
• Create the option to choose among several years to roll out of the arrangement by funding several sleeper GRATs alongside the ILIT
• When the right rollout year rolls around, one of the sleeper GRAT’s remainder repays the premium loans
• The other sleeper GRATs simply pour the low yielding assets back to the grantors over the remainder of their terms
Potential concerns:• Don’t want to make large gifts• Access to Policy Cash Values
Mr. and Mrs. Krepps
Hypothetical case facts:• Mr. and Mrs. Krepps, ages 45 and 44• Seven figure income and $30MM net worth• Need life insurance; interested in its role in
estate protection• Want to allocate $100,000 yearly over 10
years for premiums
This is a hypothetical example used for illustrative purposes only to describe how the strategies may work. Which strategy works best for clients will depend on their individual facts and circumstances. Actual results will vary. Any representation of life insurance premium or death benefit is purely hypothetical in amount and is not a guarantee of cost or death benefit now or in the future from a specific life insurance policy. Any assumptions for life insurance policy values on subsequent slides are based on a male age 45, Preferred Non-Tobacco underwriting class, and female, age 44 and Preferred Best underwriting class, PruLife SUL Protector, $108,750 annual premium for 10 years, $10,000,000 Level death benefit. The rates for the SUL are Current Assumptions.
Family Split Dollar Arrangement
• Need $10 Million of Life Insurance• 10 Pay Premium To Guarantee DB through
Mrs. Krepps’ Age 105 = $108,757
This hypothetical example is for illustrative purposes.Actual results will vary.
Sample Case
Family Split Dollar Arrangement with Sleeper GRAT
Beneficiaries (estate tax-free, if structured
properly)
Irrevocable Life Insurance Trust
Second-to-Die Cash Value Life
Insurance Policy
$5,000,000 GRAT funding
$108,757 annual premium loans
$562,474 annuity Payment
Collateral assignment (ILIT)
Loan interest payment (ILIT)
Access to trust values by spouse, if necessary
Death benefit proceeds distributed on the second death
Mrs. Krepps
1
2
3
4
1
2
4
3
Mr. Krepps(sole grantor of ILIT)
Mrs. Krepps(co-grantor of GRAT)
10 Year Sleeper GRAT (and other
GRATs with different terms)
Fixed Income Assets
ILIT is Remainder Beneficiary
1
2
2
Sample Case
After 7 Years
Mr. Krepps(sole grantor of ILIT)
Mrs. Krepps(co-grantor of GRAT)
1
2
10 Year GRAT
High Yield Assets
ILIT is Remainder Beneficiary
1
2
$1,615,807 high yielding assets
$1,615,807 Fixed Income Assets
$5,000,000 total transferred to GRAT
$1,087,570 total loan to trust
Cum. Annuity payments: $5,062,262
Collateral assignment: $1,087,570
Cash value share: $672,988 (actual surrender value)
Death benefit share: $1,087,570
Cum. loan interest payments $119,633
Access cash value: $0
ILIT share of death benefit : $8,912,430
Sample Case
In 10 Years – Beginning of Year
Mr. Krepps(sole grantor of ILIT)
Mrs. Krepps(co-grantor of GRAT)
Beneficiaries (estate tax-free, if structured
properly)
Irrevocable Life Insurance Trust
Second-to-Die Cash Value Life
Insurance Policy
Mrs. Krepps
1
2
3
4
1
2
4
3
10 Year GRAT
High Yield Assets
ILIT is Remainder Beneficiary
1
2
2
Final annuity payment of $562,474
$1,098,027 GRAT remainder paid to ILIT
$1,087,570 loan paid back to Mr. Krepps
Cash value available to access, if necessary: $776,365
ILIT share of future death benefit proceeds: $10,000,000
Sample Case
In 10 Years – End of Year
Mr. Krepps(sole grantor of ILIT)
Mrs. Krepps(co-grantor of GRAT)
Beneficiaries (estate tax-free, if structured
properly)
Irrevocable Life Insurance Trust
Second-to-Die Cash Value Life
Insurance Policy
$10,457 Unspent GRAT Remainder
Mrs. Krepps
2
3
4
2
4
3
10 Year GRAT
Terminated, No Remaining Assets
2
1
12
Results
• Clients receive back value equal to all of their GRAT transfers, plus time value of money
• Clients had 10 years to re-tool non-GRAT investments, get higher returns
• Favorable investment returns channeled to benefit the next generation with no transfer tax
• Premium loans are paid back to the clients
• Excess remainder value stays in ILIT to benefit heirs
Benefits
Getting Started
Talking Points• Do you know some of the benefits that low interest rates
could provide for your wealth transfer planning?
• Are you aware of the factors that may bring the economy out of this low interest rate environment?
• “We don’t want to give up control of our assets.”
• If you could find ways to minimize the loss of control over your assets, would you be interested in knowing more?
• Let me share an idea with you…
NOT FOR CONSUMER USE32
Next Steps• Individual meeting
• Identify prospects
• Build and present case
Clients Who May Benefit High Net Worth ($10MM+) and family
oriented
Are concerned about the impact of transfer taxes on their financial legacy
Have sufficient income from other sources, besides the assets used in the strategies
NOT FOR CONSUMER USE33
• Enter the advanced planning club.
• Help clients to take action now.
• Preserve and/or increase assets under management (AUM).
• Support and Resources
What’s In It For You?
NOT FOR CONSUMER USE34
Summary
Why This Strategy, Why Now• Taking advantage of low interest rates using the strategy described
here can help to enhance wealth for heirs.
Why Life Insurance• Life insurance is essential in managing the risks inherent in the
strategy, and may also further enhance the amount of wealth going to heirs.
Getting Started• Implementing the strategy using simple talking points and our
resources
NOT FOR CONSUMER USE35
Important ConsiderationsBefore implementing this strategy• Clients should consider developing a comprehensive financial plan to take into account
current and future income and expenses in conjunction with implementing any of the strategies discussed here.
• We recommend that clients consult their tax and legal advisors to discuss their situation before implementing any strategy discussed here.
About this concept• This concept is only suited to high net worth clients who do not rely on the assets for living
expenses for the expected lifetime of the insured(s). It is the client’s responsibility to estimate these needs and expenses and it is recommended that they consider developing a comprehensive financial plan in conjunction with implementing the strategy being considered. The accuracy of determining future needs and expenses is more critical for clients at older ages who have less opportunity to replace assets used for the strategy.
If your client’s financial or legacy planning situation changes• If clients need to use the assets or income in the strategies for current or future income
needs and they can no longer make premium payments, the life insurance death benefit may terminate and the results illustrated may not be achieved.
36
Important ConsiderationsTax and other financial implications• There may be tax and other financial implications as a result of liquidating assets within an
investment portfolio. If contemplating such a strategy, it is important for clients to understand that life insurance is a long-term strategy to meeting particular needs.
About life insurance• The death benefit protection offered by a life insurance policy can be a key component of
a sound financial plan. It is important for clients to fully understand the terms and conditions of any financial product before purchasing it.
Other notes• Clients should consider that life insurance policies contain fees and expenses, including
cost of insurance, administrative fees, premium loads, surrender charges, and other charges or fees that will impact policy values.
• If premiums and/or performance are insufficient over time, the policy could lapse, which would require additional out-of-pocket premiums to keep it in force.
37
Important InformationThis material has been prepared by The Prudential Insurance Company of America to assist financial professionals. It is designed to provide general information in regard to the subject matter covered. It should be used with the understanding that we are not rendering legal, accounting or tax advice. Such services should be provided by the client’s own advisors. Accordingly, any information in this document cannot be used by any taxpayer for purposes of avoiding penalties under the Internal Revenue Code.
PruLife® SUL Protector is issued by Pruco Life Insurance Company, except in New York where, it is issued by Pruco Life Insurance Company of New Jersey. Both are Prudential Financial companies located in Newark, NJ. [Each is solely responsible for its own financial condition and contractual obligations.
NOT FOR CONSUMER USE38