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Takeaways on Investor Control

Takeaways on Investor Control

Webber v. Commissioner highlights how courts will apply this doctrine to private placement life insurance

Many articles1 have been written about the recent investor control case, Webber v. Commissioner.2 In Webber, the Tax Court found the policyholder personally liable for taxes on income earned on assets held in separate accounts that supported offshore private placement life insurance (PPLI) policies, because he maintained excessive control over the policies’ assets and, therefore, was considered their owner for tax purposes. While the facts in the

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