The question has an answer, and the answer is a date rather than a yes. A policy replaces the tax a portfolio pays each year with charges it pays each year. Whichever is smaller wins, and the interval before the structure has repaid what it cost to put in place is the break-even.
Open the instrumentNothing is transmitted and nothing is stored. Every charge is yours to enter.
Most of the argument about private placement life insurance is conducted in adjectives. The economics are not complicated, and they are arithmetic.
The first thing that decides the answer is how much tax the portfolio actually pays each year — not the marginal rate, but the drag the strategies produce given how they earn. A portfolio of private credit and taxable bonds surrenders a large share of its return annually, at ordinary rates, as it arises. A portfolio of buy-and-hold equity surrenders very little, because almost nothing is realised. Two families in the same tax bracket can be a hundred basis points apart, and the one paying less has correspondingly less for a structure to save.
The second is what the contract charges. That is the layer nobody publishes: no carrier writing this business discloses a cost-of-insurance scale or a rate card, and what circulates instead is convention repeated between intermediaries. The itemisation of those layers, and what each of them pays for, is set out in PPLI costs and economics. This page does not restate it. It takes the numbers from the proposal in front of you and does the sum.
The third is the one most illustrations leave implicit: how the money eventually comes out. Held until death, policy proceeds are excluded from gross income — and the taxable account, on the same event, has its basis adjusted to fair market value, so the gain it has been deferring for thirty years is never taxed either. Surrendered for cash, the policy's gain is ordinary income while the taxable account settles at the long-term rate. The same contract, the same charges and the same portfolio produce opposite answers on those two assumptions. An illustration that does not say which one it is using is not telling you what it computed.
The same money, held two ways, year by year. Enter the charges from an actual proposal; the recurring charge is the only field that arrives with a figure in it, and that figure is a convention rather than a price. Where the structure does not repay its cost, the result says so.
Both sides run on the same engine as the Portfolio Tax Drag Calculator and the Wealth Simulator. There is one model of after-tax compounding on this site, not three: enter the same portfolio in any of them and the tax figures agree exactly.
The taxable side is a year-by-year simulation rather than a formula, because cost basis matters. Each sleeve earns its stated return net of its own fee; the part paid out as income is taxed as it arises, at ordinary or preferential rates according to its character; the part left as appreciation is taxed only when turnover realises it. Tax is paid out of the portfolio, after-tax proceeds are reinvested, and basis steps up by what has been realised. The portfolio is rebalanced to target weights each year with basis carried proportionally.
charges = value × recurring rate + cost of insurance + admin
value = (value − charges) × (gross return − fee)
Inside the wrapper nothing is taxed as it arises, so the character of the income and the turnover of the strategies stop mattering; the policy simply compounds at the portfolio's return after the same management fees the taxable account pays, less its own charges. Premium loads, any federal excise and the one-off structuring cost come out before a dollar is invested, which is why they dominate the early years.
One detail is worth stating because proposals routinely gloss it. A charge of a hundred basis points levied on account value is not the same as a hundred basis points subtracted from the return: the charged amount is taken out and then does not earn anything, so the true cost compounds slightly against you. This model charges on value, which is what the contract does. On a 10% gross return the difference is 2.07 times the taxable account after twenty years rather than 2.11 — small, but in the direction of the policy costing more than the shorthand suggests.
The exit is applied to both sides at every year, so the two lines are directly comparable at any point rather than only at the end. Held to death, both sides are taken at value: the policy under the exclusion at 26 U.S.C. §101(a)(1), the taxable account under the basis adjustment at §1014. The death benefit in excess of cash value is ignored, which understates the policy — the net amount at risk depends on mortality assumptions this model has no basis to make. On surrender, gain above investment in the contract is ordinary income under §72(e)(5); the taxable account liquidates at the long-term rate.
The break-even year is the first year in which the policy is ahead and stays ahead. Where the two never cross, the instrument reports no break-even rather than extrapolating to a year beyond the horizon entered.
Six things it is worth knowing before the output is used for anything.
Every charge is supplied by the reader. The recurring charge opens at 100 basis points because that is the midpoint of the 50 to 150 basis point range PPLI.com reports as market convention in costs and economics — convention repeated between intermediaries, not a figure any carrier has disclosed. Replace it. The cost of insurance opens at zero because there is no defensible default for a mortality charge, and the instrument withholds a favourable verdict entirely while that field is empty.
Every sleeve earns its stated return every year. There is no volatility and no sequence-of-returns risk. This matters more here than in a pure projection, because a structure whose break-even sits at year 21 is depending on two decades going roughly to plan.
Borrowing against a contract rather than surrendering it is the mechanism generally used in practice to reach cash without triggering the gain. Loan rates, spreads and lapse risk are contract-specific, and assuming them would flatter the structure, so withdrawals are modelled as withdrawals: tax-free to the extent of investment in the contract under 26 U.S.C. §72(e)(5)(A)(ii) and (5)(C), ordinary income above it. Liquidity and policy loans covers the mechanism.
The whole calculation presupposes that the arrangement is life insurance for tax purposes and is treated as such. The definitional limits at 26 U.S.C. §7702, the diversification requirements at §817(h), the modified endowment rules at §7702A and the investor control doctrine are conditions, not inputs, and this model does not test any of them. Nothing here establishes that a given structure meets them — see the definitional and diversification framework and investor control, and take the question to counsel on the specific facts.
The ordinary and long-term rates entered apply for the whole horizon. Over thirty years that is a strong assumption in both directions, and it is the reason the sensitivity matrix exists: a break-even that only survives at one rate is not a finding.
Estate treatment, creditor exposure, succession, governance and reporting are outside this arithmetic, and for some families they decide the question on their own. A favourable break-even is not a recommendation, and an unfavourable one is not advice to do nothing.
Ten million dollars, thirty years, held to death, at 40% ordinary and 25% long-term. Identical charges on both: a 1.2% premium load, $150,000 of structuring cost, a 1.00% recurring charge, $45,000 of cost of insurance growing at 4%, and $20,000 a year of administration. Those figures are round numbers chosen to be easy to check, not a quotation.
| Income-heavy | Low-turnover equity | |
|---|---|---|
| Gross return | 6.70% | 6.98% |
| Management fees | 93 bps | 38 bps |
| Tax drag, year one | 168 bps | 64 bps |
| After-tax, after-fee return | 4.08% | 5.95% |
| All-in policy charge, year one | 165 bps | 165 bps |
| Taxable account at 30 years | $31,645,653 | $48,715,213 |
| Inside the policy at 30 years | $32,441,753 | $41,722,496 |
| Tax paid over 30 years | $10,355,652 | $8,926,470 |
| Charges paid over 30 years | $8,917,539 | $9,785,169 |
| Break-even | Year 21 | Never |
| Position at 30 years | $796,100 ahead | $6,992,717 behind |
The income-heavy portfolio — private credit at a quarter, taxable bonds at thirty per cent — loses 168 basis points a year to tax and would pay 165 inside the contract. That three-basis-point margin is the entire engine of the result, and it takes twenty-one years to repay the load and the structuring cost. The advantage is real and it is $796,100, which on ten million dollars over thirty years is roughly two and a half per cent. It is not nothing. It is also not the transformation the category is usually sold as, and it disappears if the recurring charge is quoted at 125 basis points rather than 100.
The equity portfolio never crosses. It defers almost everything it earns, so there are only 64 basis points a year for a wrapper to remove, against 165 of charges. Worse, because it compounds faster, its recurring charge is levied on a larger balance every year: it pays more in charges over the thirty years than the income portfolio does, $9.79 million against $8.92 million, while having less than half the tax to save. The taxable account finishes seven million dollars ahead. That is the correct answer, and it is the answer for a great many portfolios that get shown a policy illustration.
One further point about the first portfolio, since it is the favourable case. None of its $796,100 comes from the tax on the terminal gain. The taxable account was credited with the basis adjustment at death in exactly the same way, so the deferred gain it had been carrying was never taxed either. The whole advantage is the tax paid year by year along the way. Change the exit to a surrender and the same case reverses completely: the policy's gain is taxed at 40% rather than 25%, and it ends $7,475,644 behind, having never crossed at all.
Four provisions do the work in this calculation. They are cited because the model applies them, not to establish that any structure qualifies for them.
Gross income does not include amounts received under a life insurance contract where those amounts are paid by reason of the death of the insured. The general rule carries exceptions at §101(a)(2) for transfers for valuable consideration and at subsections (d), (f) and (j), none of which this model applies. Read the section.
The basis of property acquired from a decedent is its fair market value at the date of death. This is why the held-to-death comparison credits the taxable account with the same relief the policy receives on its terminal gain, and why the policy's advantage on that exit comes entirely from tax avoided during the holding period. Read the section.
The general rule at §72(e)(2)(B) includes such amounts in income to the extent allocable to income on the contract. For a life insurance contract, §72(e)(5)(A)(ii) and (5)(C) reverse that ordering, including the amount in gross income only to the extent it exceeds the investment in the contract — basis first. Paragraph (10) removes that treatment for a modified endowment contract under §7702A, in which case income comes first. Withdrawals and surrenders in this model follow the §72(e)(5) ordering and are taxed at the ordinary rate. Read the section.
A federal excise of one cent on each dollar of premium applies to a policy of life insurance issued by a foreign insurer. It does not apply where the insurer has elected under §953(d) to be treated as a domestic corporation, which is the common arrangement. The toggle in the instrument is off by default for that reason; turn it on only if the proposal indicates otherwise. Read the section.
Two further points on what is not here. No carrier writing private placement life insurance publishes a charge schedule, and the most prominent public examination of the sector to date reported aggregate market size without any carrier charge data. Nothing in the public record establishes a market price for these contracts, which is why this instrument asks for yours. State premium tax is the one cost layer that is genuinely published and varies by domicile; both it and the treatment of the deferred acquisition cost capitalisation at §848 are set out in costs and economics.
Bring the proposal and the portfolio. Read personally by a senior specialist, with a written reply usually within one business day.
Confidential PPLI ReviewYour information is submitted over an encrypted connection and handled in accordance with our Privacy Policy. PPLI.com does not sell personal information. Any external introduction is made only with your permission.