cratchit.

Private placement life insurance

High cautionIRC §7702, §817(h)For business owners and employees

High caution: explained, not promoted.

Cratchit rates private placement life insurance High caution. It's explained here so you can understand it if it's pitched to you, not recommended.

PPLI is a life insurance policy built for very wealthy investors. It holds investments such as hedge funds or private funds inside the policy, so their returns grow without yearly tax. Premiums usually run into the millions, and the arrangement has drawn close attention from the Senate and the IRS.

How it works

A life insurance policy built for wealthy investors that holds investments like hedge or private funds inside it, so their returns grow without yearly tax. Usually needs million-dollar premiums.

What makes it hold up

Risks

High scrutiny. If you control the investments yourself, the IRS treats you as the owner and the tax benefit disappears. The Senate has looked closely at how it’s used. The policy is a private securities offering, open only to qualified investors, and costs vary widely between carriers, so compare the insurance charges and fund fees, not just the projected growth.

Questions to ask your CPA

Common questions

Who is it for?

Investors with very large portfolios who qualify for private securities offerings. It usually requires premiums in the millions of dollars.

What makes it lose its tax benefit?

Control. If you direct the specific investments yourself, the IRS treats you as owning them and the tax shelter disappears. Investments must also be diversified within the insurer's account.

Why is it scrutinized?

Congress has examined how wealthy families use it to shelter investment gains. Arrangements that blur the line on control are the main concern.

What should I compare?

The insurance charges and fund fees across carriers, not just projected growth. Costs vary widely.

See what this would mean for your family

Cratchit runs every strategy in this library against your real numbers, rates it, and keeps the records that make it hold up. Take a guided tour with the Harpers, a sample family.

Try the demo

Related strategies

Education, not advice. Tax law changes and every situation is different, so confirm the details with your CPA or tax advisor before acting. This page was last checked against tax law as of October 2026, including the 2025 tax law, in October 2026.