Law Office of Thomas J. Swenson
U.S. and International Wealth Building and Wealth Preservation
Legal and U.S. Tax-Law Compliant

DYNASTY TRUSTSCAPTIVE INSURANCERETIREMENT & ESTATE PLANS
IRREV. LIFE INS. TRUST (ILIT)MEDICAID TRUSTSPRE-NUPTIAL PLANS

OFFSHORE ASSET PROTECTIONINTERNATIONAL LLCsPRIVATE PLACEMENT LIFE INSURANCE

INTELLECTUAL PROPERTYBUSINESS PLANNING

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  • KEEP YOUR WEALTH: TAX-EFFICIENT WEALTH BUILDING AND ASSET PROTECTION

    An irrevocable life insurance trust (ILIT) is a 100% tax-efficient structure that builds and preserves wealth, while eliminating all taxes legally. In addition to providing a life insurance benefit, an ILIT enables tax-free growth, tax-free distributions to beneficiaries, and tax-free family wealth transfer in complete compliance with U.S. tax law. An ILIT provides asset protection and low-risk market-linked growth, while continuing for generations, even perpetually. Business owners: To protect your business and build more wealth, click CAPTIVE INSURANCE COMPANIES on the menu bar above.

     

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  • LIFE INSURANCE POLICY PROTECTION

    Private placement life insurance (PPLI) allows tax-free investment growth in segregated policy accounts, especially useful for portfolios holding hedge funds or other short-term high-return investments. Because assets in PPLI are in segregated accounts, they are protected against insolvency of the insurance company.  When an irrevocable life insurance trust (ILIT) owns the policy, the policy and its proceeds are protected against unforeseen future creditors of the insured and beneficiaries. Foreign PPLI typically has a minimum premium commitment of at least $1 million.

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  • ENHANCED GROWTH AND PROTECTION OFFSHORE

    Captive insurance companies, life insurance and deferred variable annuity (DVA) policies in Liechtenstein, the Bahamas, and other offshore jurisdictions can be designed for full compliance with U.S. tax laws to maximize tax saving and investment growth. Offshore vehicles generally have greater funding and investing flexibility than US-based counterparts. Fees and minimum premium commitments are less than in the US. Asset protection is stronger, especially when an offshore trust owns the asset. Offshore structures combine benefits of legal tax shelters with enhanced protection and growth.

  • Self-Settled Discretionary Asset Protection Trust Not Part of Estate

    Summary: An IRS ruling provided some clarity and reassurance to US taxpayers who want to be beneficiaries of a self-settled, irrevocable, discretionary asset protection trust. In Private Letter Ruling (PLR) 200944002, the IRS ruled that assets in an asset protection trust were not includable in the grantor’s gross estate even though the grantor was a beneficiary of the trust.

    In these times of eroding property rights, punitive tax rates, and financial insecurity, a U.S. taxpayer can use an irrevocable life insurance trust to protect trust property against creditors,...

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The Law Office of Thomas J. Swenson provides custom legal services for tax-efficient wealth building and wealth preservation, domestic and international asset protection, estate planning, business planning and intellectual property law.  Clients receive expert attention to their legal, business and financial matters.

Knowledge of domestic and offshore trusts and business entities (e.g., LLCs), U.S. tax laws and tax-efficient investments enables innovative crafting of integrated wealth building and wealth preservation structures. For example, in full compliance with U.S. tax law, an irrevocable life insurance trust (ILIT) holding a life insurance policy provides a life insurance benefit, asset protection, tax-free cash-value growth, tax-free policy withdrawals and loans, and generational wealth transfer free of income, estate and generation skipping transfer (GST) taxes. With individual lifetime gift tax and GST tax exclusions currently set at $13 million, $26 million per couple (until 2026, unless reduced sooner), now is the time to fund an ILIT dynasty trust. For U.S. business owners, a section 831(b) “captive insurance company” improves business insurance coverage, as well as providing valuable asset protection and substantial tax savings. An international LLC can provide asset protection like an irrevocable trust, but at a fraction of the cost and without being irrevocable. Transfers of assets into domestic or offshore structures protect businesses and family wealth against unjust court judgments, angry ex-spouses and financial mis-mangement.

WARNING AND DISCLAIMER
Except as may be specifically described in a fully-executed client engagement letter, Thomas J. Swenson is not your attorney and you will not rely upon him for any advice, counsel or suggestions.
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Internal Revenue Service Circular 230 Disclosure: As provided for in Treasury regulations, advice (if any) relating to federal taxes that is contained in this website (including attachments and links) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein.
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