• Increase in Transparency and Fiscal oversight through multilateral agreements of cooperation and information exchange:
  • EU Savings Directive (2003)
  • FATCA (2010)
  • OECD CRS (2017/18)
• Governments are looking for immediate alternatives to increase it’s fiscal revenues and are changing international legislations for fiscal audits:
  • Controlled Foreign Corporation (CFC) laws;
  • General Anti-Avoidance Rules (GAAR); and/or
  • Inheritance taxes

Experiences with other markets

(Brazil, Chile, Holland, Argentina, Mexico, Colombia and Spain)

• ax reforms and Amnesties = Opportunity to Restructure
• Revise strategies for a more efficient Equity and Assets transfer
• Reinstatement of property losses due to taxes and fines.
• Take advantage of the recognized and significant tax advantages, Asset multiplication and asset protection offered globally for decades by the insurance industry.

Strategy of Inheritance Maximization

Case study – Brazil

Customer Profile and objective:

• In 2005, a 50 year old client created and offshore investment account and remitted $5 million. Today this account has a market value of approximately $10 million. Customer is seeking to maximize the net values of their inheritance and at the same time keep their liquidity in life for any contingency.

Tax Benefits of life insurance distribution:

Alternatively, if the client allocates his capital gains of $ 5 million and invests them in a Universal Life insurance policy, he would have the following tax treatment:

• In Brazil, upon distribution, the benefits of a life insurance are EXEMPT from the following taxes:
  • Capital Gain Tax
  • Inheritance Tax (ITCMD)
  • Income Tax
  • Exchange Rate Tax

*IOF tax of 0.38% of the financial transaction is due