Private placement life insurance is among the most powerful tools available to high-net-worth families for tax-efficient investment growth, estate planning, and intergenerational wealth transfer. It is also among the most technically demanding instruments to structure correctly.
The IRC §7702 definitional requirements, §817(h) diversification mandates, the investor control doctrine, and — where offshore carriers are involved — the §953(d) election and the foreign reporting regime combine to create a legal framework in which small structural errors can unwind the policy's tax treatment entirely. The economic stakes of these errors, on policies sized for the HNW and UHNW market, are substantial.
The Law Office of Gordon Platt, P.C. provides outside legal counsel to PPLI policyholders, their carriers, and their existing advisors on structuring, ongoing compliance, and integration with trust and estate plans. We do not sell insurance products. We function as the legal architecture review the structure requires.
Our PPLI engagements typically address:
A meaningful portion of sophisticated PPLI work uses offshore carriers — particularly those domiciled in Barbados, Bermuda, and the Cayman Islands — for premium tax efficiency, regulatory flexibility, and a broader range of separate account investment options. Offshore PPLI introduces a layer of legal complexity that domestic structures do not, and requires careful coordination across multiple bodies of law.
Our offshore PPLI work addresses:
We work regularly with Barbados-domiciled carriers and have particular familiarity with the regulatory environment of the Barbados Financial Services Commission and the structuring conventions used in the Barbados PPLI market for U.S. clients.
Most PPLI clients arrive with established advisor relationships — a primary trust and estates attorney, a CPA or tax advisor, a wealth manager, often a family office, and the carrier itself. Our role is to provide the specific legal counsel the structure requires without disrupting those relationships.
We work directly with carrier counsel on policy issuance and structural questions. We coordinate with the client's primary T&E attorney on trust ownership and beneficiary architecture. We work with the CPA on tax reporting and ongoing compliance review. We do not bill duplicatively for work the existing team is handling, and our engagements are scoped narrowly to the legal questions PPLI specifically raises.
Carrier representatives, family offices, and primary advisors who refer matters to us can expect that the client relationship returns to them on completion of the structuring work.
Gordon Platt founded the Law Office of Gordon Platt, P.C. after a career as an Emmy-winning investigative producer at ABC News Nightline. He holds a J.D. from Harvard Law School, a B.A. summa cum laude from Dartmouth College, and graduate study from the London School of Economics.
The firm's PPLI practice draws on the same forensic insurance contract expertise developed through its cost-of-insurance overcharge litigation against major U.S. life insurance carriers — work that requires close reading of policy forms, separate account agreements, §7702 compliance language, and the operational mechanics of how insurers actually administer cash value, COI, and expense charges. That depth of contract-level familiarity is unusual for outside counsel in the PPLI space and produces structuring that holds up to scrutiny.
To discuss a PPLI engagement — whether you are a prospective policyholder, an advisor evaluating counsel for a client, or a carrier representative coordinating outside legal review — please contact the firm directly.
Initial conversations are confidential and without obligation. We typically respond within one business day.