News & Analysis as of

Internal Revenue Code (IRC) Private Placement Life Insurance

Gerald Nowotny - Law Office of Gerald R....

To Be or Not to Be Contemplating the Meaning of Life Through Private Placement Life Insurance

The focus of this article illustrates why private placement life insurance (“PPLI”) is the best asset to utilize in the “Buy, Borrow and Die” strategy for high net worth investors including billionaires. After this article,...more

Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Gerald Nowotny - Law Office of Gerald R....

(A)ESOP’s Fables – The Income and Estate Tax-Free ESOP

If the pandemic was good for anything, it was TV watching. The pandemic may become known as the golden age of television. Since I was a foreign language major (Portuguese and Spanish) at West Point (mind you out of academic...more

Gerald Nowotny - Law Office of Gerald R....

TAKE A CHANCE ON ME! Part II

Embracing the Magic of Private Placement Life Insurance (PPLI) and Private Placement Variable Annuities (PPVA) - I am happy to be back from my writing hiatus. In retrospect I am not really certain what the reason was for...more

Gerald Nowotny - Law Office of Gerald R....

Carajo – There’s Gold in Them Thar Hills!

The New Gold Rush- The Use of Private Placement Insurance Products for Managing Bitcoin and Other Crypto-Currency Trading - Overview - Someday when CNN creates a documentary of the early 21st century, the story of...more

Gerald Nowotny - Law Office of Gerald R....

The Walking Dead - Using Private Placement Variable Deferred Annuity Contracts to Enhance the Investment Return in Life Settlement...

Overview - I have always been a film fan. Growing up in the Panama Canal Zone, one of my Mother’s jobs for the Panama Canal Company was serving as the manager of the Balboa Theater. We used to watch initial screenings of...more

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