Split Funded Defined Benefit Plan under IRC § 412

 

 

 

A depressed economy and stock market fluctuations have reduced the value of most retirement accounts in recent years.  Combined with an uncertain economic outlook, many business owners and professionals are hesitant or are unwilling to make long-term commitments.  

 

Increased costs of living and longevity makes business owners and professionals aware they will need a larger nest egg to maintain their desired retirement lifestyle.   Many business owners and professionals are looking to defined benefit retirement plans under Internal Revenue Code, Section 412 (IRC§ 412).

 

 

 

 

A defined benefit plan under the IRC§ 412, is a retirement strategy funded exclusively with life insurance contracts.   Compared to other types of tax-qualified plans, IRC§  412 pension plans are:

 

 

 

Maximize Your Business Deductions and Secure Retirement Benefits

 

 

The Pension Professionals Hybrid 412 Plan is a unique retirement plan for business owners and professionals offering large deductible contributions, steady, tax-deferred earnings, optional tax-free distributions prior to age 59 1/2, while minimizing contributions employers must allocate to their employees.

 

Financial and retirement planning objectives that many business owners and professionals have volunteered to us include:

  1. Maximize employer and key employee contributions on a pre-tax basis
  2. Minimize contributions for funding employee benefits
  3. Significantly reduce or eliminate taxes
  4. Access retirement benefits on a tax favored basis (i.e. not merely defer the tax)
  5. Protect retirement assets from creditors
  6. Achieve substantial wealth transfer if estate taxes are a consideration
  7. Avoid stock market volatility with guaranteed returns
  8. Integrate the strategy with other life and estate issues
  9. Integrate the retirement strategy with other life and estate issues

 

Highest Allocation to You

We can re-design an existing plan.  The following table shows the previous client using alternative strategies for a dental practice of 55 year old dentist who employs the spouse, five other employees and uses a PPI Hybrid 412 Plan and a profit sharing plan:

 

 

 

 

Pension Professionals Hybrid 412 Pension Plan Design

 

As with most financial strategies, there are substantial tradeoffs.  However, there is one strategy that allows business owners and professionals to achieve all the major objectives listed above - Pension Professionals (PPI) Hybrid 412 Plan.

 

In addition to supporting the above-listed objectives, the PPI Hybrid Plan design is supported by an IRS Determination Letter.

 

When the advantages available under IRC§ 412 are combined with an optional strategy (for a buyout and exchange of the life insurance policy under section 1035 for a better performing policy or another investment alternative), taxpayers gain the ability to access large amounts of tax-free distributions during retirement while simultaneously removing pension assets from his/her estate.

 

Example 1 – Comparison of Qualified Plans

Doctor and Spouse:

 

 

 

 

Qualified Money Conversion™ Program

 

If you already have an existing retirement or pension plan, IRA, IRA rollover, beneficiary IRA a qualified money conversion strategy should be considered.  Qualified funds are subject to both income and estate taxes.  Consequently, they are worth only 25 cents on the dollar (assuming estate taxes of 28% to 45%).   Pension Professionals, Inc. offers strategies for converting these qualified funds to give you 90 cents to ten times the dollar, access to substantial tax-free withdrawals, while excluding these amounts from your estate.

 

Client Profile:

 

·         Net Worth $5 Million or above

·         Realizes the $1 Million is worth $600,000 in his/her hands and $300,000 to heirs

·         May want some cash flow bust doesn’t need nor want the money

·         Wants to reduce Required Minimum Distributions  (RMDs)

·         May be adverse to leverage

·         Must have an active trade or business

·         May want guaranteed death benefit or wealth transfer amounts

 

 

 

$1 Million Qualified Money Conversions™ Program

Value Information

(000)

 

55 Yrs.

65 Yrs.

75 Yrs.

85 Yrs.

Low Value at Age 90

$ 6,000k

$ 3,000k

$2,000k

$1,000k

High Value at age 90

$ 15,000

$ 7,500

$ 4,000

$ 2,000

Wealth Multiplier Range

5 to 13 Times

5 to 13 Times

6 to 12 times

3 to 7 times

 

$1 Million Qualified Money Value Information

(000s)

Withdrawal Value

$  600

$  600

$  600

$  600

Value to Heirs – Now

$  340.6

$  340.6

$  325.8

$  317.6

Value to Heirs – Age 90

$1,133.6

$  576.2

$  344.5

$  302.2

Client’s tax cost utilizing Rev. Rul 2005-25 Safe Harbor PERC Values:

Approximately $250,000 to $60,000 could even be less

 

 

 

Comparability Plans

 

A very popular retirement plan for business owners and professionals that also provides a large share of discretionary profit sharing contributions to the owners is the Comparability Plan.   These plans allow allocations that can’t be achieved in any other type of retirement plan.  This allows the business owner or professional to tailor the plan to meet his/her specific needs and goals. 

 

 

Introduced in 1990, these plans are designed to be “safe harbor” plans and have reasonable fees. ($ 1,500 set up and $ 1,500 annual administration for small plans).  Some of the advantages include:

·         Employers may contribute for themselves and their spouse (if employed) and/or key employees up to 100% of wages.

·         Business owners’ maximum contribution is 100% of wages up to $45,000 annually per participant, while contributions for employees can be as low as 5% of compensation.

 

·         Employers may cover employees with more than one year of service, who are over the age 21

·         Vesting can be on a graduated schedule of 20% per year, which results in an employee being 100% vested after six years of employment.  

·         Overall contribution is limited to 25% of eligible compensation.

·         PPI obtains an IRS Determination Letter on each of these plans.

PPI’s Unique Design

Pension Professionals, Inc.’s unique plan design funds Comparability Retirement Plans with 49% of the contribution in life insurance.   Participants may elect to opt out of life insurance coverage and elect an annuity or side-fund investment instead.  Employers may enjoy benefits of:

 

About Pension Professionals, Inc.

 

 

Pension Professionals, Inc. (PPI) is an independent designer and distributor of asset protection and wealth transfer retirement planning solutions to high net worth individuals and business owners.   It was founded in 1988 in Oregon by Dennis Cunning. Pension Professionals, Inc. and Pension Professionals LLC is now headquartered in St. Thomas, US Virgin Islands with an affiliate offices in Phoenix, Arizona. 

 

Our mission is to provide the perfect retirement plan design that achieves:

 

 

 

Dennis Cunning, Manager and Member of Pension Professionals, Inc., LLC, is founder and developer of the Hybrid 412 Pension Plan Design.   After practicing public accounting in Oregon for over 25 years, Mr. Cunning has authored various texts and taught courses on retirement planning.  In 1996, he retired his CPA certificate from active public practice.

 

Pension Professionals, Inc.

6501 Red Hook Plaza, #201

St. Thomas, VI 00802

340-714-0510  Local

800.536-0510   Toll Free

340-775-2822  Fax

 

For a free feasibility study, email: freefeasibility@pensionprofessionals.com

 

For further information, email: marketing@pensionprofessionals.com