It has been awhile since I have written anything. Oh, the indignity of having to make a living! I hope that everyone had a great holiday season and please accept my best wishes for a happy, healthy and prosperous 2022. Most of you know by now that I am a quirky guy with quirky interests and quirky points of view. In that realm, I must say that I have always been a great fan of the Godfather of Soul, James Brown. Is it the great horn section (Maceo Parker, Fred Wesley, and Pee Wee Ellis), or is it my great dancing ability(highly unlikely?) So great was my affection for the Godfather of Soul and his horn section, that I have referred to myself as Soul Brother #2. I am most likely #99 or 100 on the list.
The year past saw the Biden Administration shoot several projectiles over the Bow of the Malta Pension Plan ending the year with the issuance of the Competent Authority Agreement. I doubt that this will be the last word about Malta Pension Plans. It is my view that the Government wants to intimidate taxpayers to end Malta Pension Plans but is very unlikely to prevail on the merits if it has to litigate.
What's left? Have I mentioned Private Placement Life Insurance (PPLI)? It is much harder to end the favorable tax treatment of life insurance without stepping on the very large toes of taxpayers who write large checks to politicians - American Council of Life Insurers, Prudential, New York Life, MassMutual Met Life et al.
PPLI has a lot to offer and I am not talking about the Tea for Two version of PPLI, e.g. policies with conventional investment options featuring institutional investment advisors. I am talking about PPLI featuring intellectual property, equipment leasing, and derivative contracts. Not only can these strategies withstand the scrutiny of investor control, the strategies deliver significant tax benefits at the policyholder and operating company level.