EFTA01470853Set 10
2014-06-109p1,257w
Subject: Re: Richard Kahn: Private Placement Variable Annuity (PPVA)
Investment Account
From: Paul Morris a>
Date: Wed, 10 Sep 20
To: Mike Liebeskind
Cc: Brian Gartner
Classification: External Communication ... Paul Morris
Cc: Brian Gartner < z•
Subject: Richard Kahn: Private Placement Variable Annuity (PPVA)
Investment Account
Paul,
I don't recall hearing back from Richard Kahn. Should I reach ... Richard Kahn'
Cc: ' ; Brian Gartner
Subject: RE: Private Placement Variable Annuity (PPVA) Investment Account
EFTA01470853
Hi Rich,
How did the meeting with your Principal go?
Michael
From: Michael Liebeskind
Sent
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01470853.pdf
inclusion of the PPVA in the estate. To the extent paid to a tax-exempt entity, the investment
income and gains within a PPVA will not be subject to income ... this opinion, you have represented the following facts are true
with respect to the PPVA:
Under the terms of a PPVA, an issuer of the PPVA will agree to make ... time, beginning no later than when the annuitant reaches age 95 or
100. The PPVA will be issued by the Insurance Company to U.S. individual investors (or to
trusts
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01454373.pdf
ordinary income? Once the amount of the owner's investment in the PPVA is fully recovered,
subsequent payments are fully included as ordinary income without reduction.
a. Recovery ofInvested Amounts ... upon Death
If the owner of a PPVA dies and the account value is below adjusted basis, the
taxpayer is generally permitted to deduct in his or her final return ... that permits the deduction to be carried back to prior tax years." If the PPVA
account value is above adjusted basis, distributions in excess of the adjusted basis are taxed
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01454375.pdf
Gifts
to the impact of potentially higher income taxes on By Year 25, the PPVA account nets more than
their giving goals. Over about 15 years, the same chari- double ... reduce ■ PPVAinvelmat aacunt (net to charity)
that burden. The solution could be a PPVA. $119156436
PPVAs allow charitably inclined individuals to main-
tain full ownership and broader investment options ... beneficiary desig-
nation at any time.
Assumes15percent ofiiMna(a9imetleeein1an8peaeltteamatter
The net result, if the PPVA investment account
ini mywreri fees tna SS rritlbri nresmient in a Vote acccurt
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01454210.pdf
EFTA01456731Set 10
2014-06-051p523w
Michael Liebeskind
Subject: FW: Private Placement Variable Annuity (PPVA) Investment Account
Paul and Rich,
The third attachment to this email is the reporting example Michael was referring to. Here ... brief description of the
document:
PPVA Sample Statement: This is a redacted version of an actual client statement for the month ending December 31,
2013. The PPVA Investment Account ... Michael Liebeskind
Subject: FW: Private Placement Variable Annuity (PPVA) Investment Account
Paul and Rich,
Here is the material Michael is referring to that will help guide the discussion.
PPVA Overview
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01456731.pdf
EFTA01454384Set 10
2013-12-311p559w
reporting example Michael was referring to. Here is a brief description of the
document:
PPVA Sample Statement: This is a redacted version of an actual client statement for the month ... ending December 31,
2013. The PPVA Investment Account has now shielded $6,537,565 of investment gains from current period taxation for
an incremental fee of $407,101. This particular ... Here is the material Michael is referring to that will help guide the discussion.
PPVA Overview: This document is a simple one-page summary of a PPVA Investment Account. Under
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01454384.pdf
adverse U.S. tax consequences typical of If your client contributes $5 million to a PPVA
offshore investments. Moreover, the client's portfolio account or taxable account and allows that money ... mestmert &cart (alter tax)
• PVJA mrestmenl anon! (after tax)
These clients could use a PPVA investment account as 2500.000
a simple, yet effective, tax-deferred savings vehicle. The
tax-deferred ... accumulation allows the PPVA account 2.0041.000 9.95410
1500.000
t1.0:6.912
1,000,000 910,12COspemismomm
9a223 44444,44-444444444—saumonow
5503.120
503.0430 $50.01MMIXIOSINVIIPSMIXIRS
s•-)oi :d elapiE? :ay-evEr
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01454211.pdf