
Frozen cash value (FCV) is best known as a private placement flexible premium variable adjustable (universal) life insurance policy that’s issued by offshore life insurance companies domiciled in tax haven jurisdictions such as Bermuda or the Cayman Islands. In 1995, when Craig Hampton developed FCV insurance, the private placement life insurance (PPLI) industry for high-net-worth individuals was in its infancy. Awareness among client advisors was nonexistent.1 The passage of time and growth of the PPLI industry for FCV life insurance has increased awareness of the product. However, it’s virtually unknown by tax attorneys and CPAs, as well as life insurance agents with wealthy clients. The evolving tax landscape suggests that FCV is a p...
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