Private Placement Life Insurance (PPLI)

Protect what you earn
Compound what you keep

Use a tax-efficient insurance structure to reduce the potential tax drag on certain alternative investments and keep more of your capital compounding over the long term.

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How Private Placement Life Insurance Works

Private Placement Life Insurance, or PPLI, combines permanent life insurance with an investment structure designed to help qualifying investors accumulate wealth more tax efficiently. After-tax capital is contributed to the policy and allocated across eligible investments, where it may grow tax deferred when applicable requirements are met.

Fund → Invest → Compound → Access

01

Fund

Contribute after-tax capital to a customized PPLI policy.

02

Invest

Allocate capital across eligible investments according to the policy’s structure and applicable requirements.

03

Compound

Reduce ongoing income-tax drag and keep more capital invested over time.

04

Access

Potentially access policy value tax-efficiently, with a death benefit that may be income-tax-free under current law if requirements are met.

Why Compounding Matters

It's not only what you earn. It's what remains invested.

Certain investments, including private credit, hedge funds and other alternative strategies, can generate tax-inefficient income. Taxes paid along the way reduce the capital available to generate future returns.

By holding eligible investments within a properly structured PPLI policy, investors may reduce ongoing tax drag and keep more capital compounding over time.

The strategy may also be relevant within certain irrevocable trusts, where income can become subject to higher tax rates at relatively low levels of taxable income.

Investment First.
Tax Strategy Second.

Tax efficiency doesn't replace investment discipline.

Start with the quality, risk and return potential of the underlying investments—then consider whether PPLI may improve the long-term after-tax outcome.

Is PPLI Right for You?

PPLI is generally designed for sophisticated investors with substantial capital and a long-term investment horizon. It requires coordination among investment, insurance, tax and legal professionals and should be evaluated as part of a broader long-term wealth strategy.

It may be worth exploring if you:

Are an accredited investor or qualified purchaser

Have significant capital available for long-term investment

Invest in tax-inefficient assets or strategies

Want to reduce ongoing tax drag on investment growth

Are considering multigenerational wealth or trust planning

Are comfortable with the complexity and requirements of a customized insurance structure

PPLI is not appropriate for every investor. Policy costs, investment restrictions, liquidity needs, insurance requirements and individual tax circumstances should all be evaluated.

Frequently Asked Questions

How is PPLI different from traditional life insurance?

PPLI generally places greater emphasis on the investment component and tax-efficient wealth accumulation than traditional retail life insurance.

It typically provides broader institutional investment flexibility and customized policy design while maintaining the life insurance characteristics required for applicable tax treatment.

How much capital is typically needed for PPLI?

There is no universal minimum across all PPLI structures.

In Peachtree's discussion with PPLI specialist Michael Parise, approximately $2 million of committed capital was identified as a level where the economics may begin to make sense, potentially funded over multiple years. The appropriate amount depends on the policy, provider and investor.

What types of investments can be held within PPLI?

Depending on the policy and provider, eligible investments may include alternative investments, private equity, private credit, venture capital, hedge funds, real estate strategies and other investments.

Available investments are subject to policy terms and applicable diversification and investor-control requirements.

How can PPLI work with a trust?

PPLI may be used within certain irrevocable trust structures as a way to hold investments more tax efficiently.

This can be particularly relevant because trusts may reach higher income tax rates at relatively low levels of taxable income. The appropriate structure depends on the family's estate plan and should be developed with qualified tax, legal and insurance advisors.

Can money be accessed from a PPLI policy?

Potentially. Properly structured permanent life insurance may allow access through withdrawals of basis and policy loans.

The tax treatment depends on the policy remaining compliant and in force, and accessing policy value can affect the policy and death benefit.

What are the risks or disadvantages of PPLI?

PPLI is complex, long-term and subject to insurance costs, investment risk, diversification requirements and investor-control restrictions.

Improper structuring, administration or policy lapse can also affect anticipated tax treatment. Investors should evaluate both the underlying investments and the costs and requirements of the insurance structure.

Does Peachtree provide tax, legal or insurance advice?

No. Peachtree provides educational information about tax-efficient investment strategies but does not provide individual tax, legal or insurance advice.

Investors considering PPLI should work with qualified tax, legal, insurance and financial professionals to determine whether the strategy is appropriate for their circumstances.

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For Use by Accredited Investors Only
Summary of Important Risks and Tax Considerations
General Investment and Private Placement Risks

Private real estate and alternative investment strategies are speculative, illiquid and involve a high degree of risk, including possible loss of principal. There can be no assurance that any investment objective, distribution target, capital preservation goal or tax result will be achieved. This summary is not complete and should be read together with the applicable offering documents, subscription materials and governing agreements.

  • Interests are generally not registered under the Securities Act of 1933 or listed on any exchange; no public market is expected to develop.
  • Investors may have limited liquidity and significant restrictions on transfer, redemption or resale.
  • Performance may be affected by real estate market conditions, interest rates, financing availability, leverage, tenant or borrower credit, operating costs, property values and sponsor execution.
  • Fees, expenses, selling commissions, broker-dealer compensation and sponsor affiliates may create conflicts of interest and reduce investor returns.
  • Past performance, targets, projections and examples are not guarantees of future results.
DST and 1031 Exchange Considerations
  • A DST may be structured to qualify as replacement property for Section 1031 purposes, but tax treatment depends on transaction structure and each investor’s facts.
  • Investors must satisfy strict exchange requirements, including identification and exchange deadlines, use of a qualified intermediary and avoidance of actual or constructive receipt of proceeds.
  • Debt replacement, cash boot, property qualification and timing issues may cause partial or full gain recognition, including depreciation recapture.
  • DST investors generally have no direct management control and limited ability to influence financing, leasing, refinancing, sale timing or property-level decisions.
  • A future step-up in basis depends on current estate tax rules and each client’s estate plan; tax law may change.
Qualified Opportunity Zone Considerations
  • QOZ benefits require eligible gain, timely investment, proper election and ongoing compliance by the investor, QOF, QROF and/or QOZ business.
  • Pre-2027 and post-2026 QOZ rules differ; rural QROF benefits, zone designations and effective dates should be reviewed with tax counsel.
  • Tax benefits may be reduced or lost if holding-period requirements are not satisfied or if the fund fails to maintain QOF/QROF or QOZ property requirements.
QOZ Development and Tax Risks
  • Development and redevelopment strategies involve entitlement, zoning, permitting, construction, environmental, leasing, valuation, financing, operating and exit risks.
  • Tax-free appreciation and depreciation recapture treatment require satisfaction of statutory and regulatory requirements and may depend on the sale structure.
  • Investors may owe tax on deferred gain before receiving liquidity from the investment.
  • Tax reporting obligations may include Form 8949, Form 8997 and other filings; penalties or inclusion events can arise if requirements are not met.
Roth Conversion and Retirement Account Considerations
  • Roth conversions generally create taxable income in the conversion year and may affect marginal tax rates, estimated taxes, state taxes, Medicare premiums, credits and deductions.
  • Tax offsets from real estate depreciation, deductions or losses are not guaranteed and may be limited by passive activity, at-risk, basis, UBTI/UBIT, plan, custodian or other rules.
  • Private real estate investments held by IRAs require an appropriate custodian and careful compliance with prohibited transaction, valuation, liquidity and reporting requirements.
  • Roth conversion planning should be coordinated with RMD timing, estate planning, beneficiary designations and the client’s liquidity needed to pay taxes from outside assets.
No Offer

This material is for discussion purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security. Any offering may be made only through definitive offering documents provided to eligible investors. Peachtree Group and its affiliates do not provide tax or legal advice. Investors should consult their own tax, legal and financial advisors before investing.