Selected Transactions

RESTRUCTURED CORPORATE SPLIT DOLLAR & ESTATE PLAN FOR COMPANY PRINCIPALS

Private firm had an outdated and inadequate split dollar plan that was originally implemented to assist owners acquire $120M of life insurance to pay estate taxes on their privately held stock, without incurring gift taxes. Apheta structured and implemented a significantly less expensive financed solution that performed better and eliminated the gift and other taxes they would have otherwise incurred. The owners still retained their desired $120M of coverage. In addition to the millions of dollars in cost savings, over the long run, the new plan performs to keep pace with the growth of the owners’ estates and eliminates the uncertainty of further legislative changes in the split dollar arena.

INTERGENERATIONAL WEALTH TRANSFER

Uninsurable clients in their late 70’s (G1) with three middle aged children (G2) and an estate in excess of $100M, consisting primarily of real estate and a privately held company, faced a looming estate tax liability that could not be addressed by acquiring life insurance. Apheta implemented a sophisticated estate planning strategy consisting primarily of a Family Limited Partnership (FLP), with the two generations as partners (G1&G2). The FLP was recapitalized into common and preferred interests with common issued to G2 and preferred to G1. Using specific provisions under current law and a substantial planning and appraisal process, the preferred interest in the parents’ estate received a 70%+ discount. The clients would save $30M+ in estate taxes, and transfer tens of millions of dollars of future appreciation in suppressed real estate and other assets to their children’s estate without incurring current gift taxes. The creative structure eventually resulted in a tremendous wealth transfer to two subsequent generations without massive erosion due to estate and gift taxes.

SUCCESSION PLANNING

Apheta used a proprietary platform to pre-fund the ownership transition of a successful auto parts distribution company from the founder to three key employees who helped grow the business. Apheta provided turn-key financing for the new owners without encumbering the business assets. The founder benefited from a favorable tax effect and high level of security in his exit, while the new owners received better financing than they could have obtained elsewhere. The transition economics and tax savings for both the buyer and seller were far more compelling than an installment sale, or similar approach.

FOREIGN NATIONAL ESTATE EQUALIZATION

Foreign national family patriarch had amassed a $400M fortune in real estate and other diversified assets over a 50 year entrepreneurial career. At age 72, with two children working in the family business and two working independently, the patriarch was retiring and had the challenge of equitably dividing his assets amongst his four children. Apheta recommended a creative estate equalization strategy whereby the business assets were transferred to those family members that were involved in running the business, while U.S. life insurance was purchased by the patriarch to create liquidity for those family members who were not involved in the business. Apheta’s solution effectively eliminated the possibility of infighting over the family assets, while perpetuating the family’s wealth rather than see it dissipate in succeeding generations.

CAPTIVE SOLUTION

Apheta helped organize and structure a domestic captive insurance company for over 300 physicians wanting to manage their medical malpractice insurance needs. The captive solution helped the group to control their premium costs while improving their underwriting profits and claims management processes.

CREATING A SUPPLEMENTAL RETIREMENT INCOME STREAM

Using a combination of low-cost financing and progressive equity-indexed insurance products, Apheta’s SIRP (Supplemental Income Retirement Program) offers a supplemental, tax-free income stream for younger clients who may have limited windows to generate income or unpredictable future cash flows (eg. athletes, young entrepreneurs, etc.). Apheta’s financial designs use the industry’s most conservative leverage and growth assumptions, assuring that clients can count on the safety-net income stream for their post-retirement planning.