Private Client Flashcards

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1
Q

goal of private wealth management

A

help investors seek the benefits as well as navigate the complexities of financial market

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2
Q

private client

A

inv. objective:

objective may not be clearly defined or quantified.

Constraints:
Time horizon: relatively short (lifelong)
Scale: smaller (more limitations)
taxes: significant and complex

investment governance less formal

distinction
Inv. sophistication:
emotional, subject to behavioral biases

regulation: separate regulation or shared regulatory structure

uniqueness and complexity:
similar objective may have different inv. strategies

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3
Q

institutional clients

A

inv. objective:

specified, clearly defined

Constraints:
Time horizon: theoretically infinite
Scale: larger
taxes: depends on institutions

investment governance: formal

distinction
Inv. sophistication:

a higher degree, professionals

regulation: separate regulation or shared regulatory structure

uniqueness and complexity:
similar objective may have different inv. strategies

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4
Q

information needed in advising private client

A
  1. personal info
  2. financial information
  3. tax considerations
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5
Q

basic tax strategies

A

tax avoidance
tax reduction
tax deferral

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6
Q

tax avoidance: TEA

A

tax exempt account TEA that investor are allowed to contribute a limit account
- various wealth transfer techniques

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7
Q

tax reduction

A

tax exempt bonds

tax efficient asset classes (stock paying a high dividend)

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8
Q

tax deferral

A

same investor in a progressive tax system seek to defer taxes because they anticipate lower futures tax rates

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9
Q

the wealth manager rols

A

goal quantification
goal prioritization
goal changes

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10
Q

private client risk tolerance

A

willingness to tolerate risk

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11
Q

risk aversion

A

unwillingness to tolerate risk

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12
Q

risk capacity

A

ability to accept financial risk, more obligate in nature

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13
Q

risk perception

A

subjective assessment of the risk involved in the outcome of an investment decision

  • questionnaire for risk tolerance score
  • risk tolerance conversion
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14
Q

capital sufficiency analysis/ capital needs analysis

A

process by wealth manager determines likely to accumulate, sufficient financial resources to meet his/her objectives

2 methods

  1. deterministic forecasting
  2. monte carlo simulation
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15
Q
  1. deterministic forecasting

portfolio growth occurs in a straight line

A
wealth manger must specify:
portfolio return assumption
current value of the portfolio 
anticipated future contribution 
CF the portfolio that represent client needs

disadvantage:
the use of single return assumption is not representative of the actual market volatility

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16
Q

2 monte carlo simulation

A

allows a wealth manager to model the uncertainty of several key variable and therefore the uncertainty or variability in the future outcome

  • assume a simple average (arithmetic mean) return and a std of YoY returns for the portfolio
  • forward looking assumption should be the foundation for the analysis
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17
Q

when the probability of success falls below the acceptable range, potential solution include:

A
  • increase the amount of contribution
  • reduce the goal amount
  • adoption an investment strategy with higher expected return
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18
Q

deterministic planing

retirement stage of life

A

education: develop human capital

early career: save for retirement goal starts
career development:

35-50 career development: financial obligation and accumulate financial capital

51-60 peek accumulation : financial capital is greatest

early retirement: lnv. portfolio fund their lifestyle

retirement: accurate financial capital

late retirement: medical expense increase
(face longevity risk)

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19
Q

analyzing relevant goals

A
  1. mortality table
    indicate individual life expectation at specific ages

potential drawback: individual clients pro. of living to a certain age may exceed that of the general population

  1. ammunities lump sum
    provide a series of fixed pmt, entire for life or for a specific period in exchange for a lump sum payment.
    It helps to mitigate the longevity risk.
  2. monte carlo simulation

adv: applicability to the client, actual asset allocation
It can flexibly model different scenario and explore issues that are important to clients
disadvantage:
it cannot predict the future due to the limitation of use of historical data
- the output is highly sensitive to small changes in input assumption
- the output indicates the prob. of reaching a good but not accessary the “shortfall magnitude”

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20
Q

immediate annuity

A

pay an initial lump sum in return for a guarantee of specific future monthly payment, beginning immediately over a specific period of time

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21
Q

deferred annuity

A

the specific future monthly payment begin at a later date

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22
Q

longevity risk

use annuity

A

risk of outliving one’s financial resources

life annuities hep mitigate it.

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23
Q

behavioral consideration in retirement planning

A
  1. heightened loss aversion
  2. consumption gap between actual and potential consumption
  3. the annuity puzzle: not prefer to invest in annuity
    - invest’s reluctance to give up hope of substantial life style
    - the dislike of losing control of assets
    - high cost of annuities
  4. preference for investment income over capital appreciation
    spending only the interest and not the principal is a self-control mechanism
    spending dividend rather then selling stock
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24
Q

IPS

A

ADV:

  1. encourage investment discipline and reinforces client’s commitment to fall out the strategy
  2. focus on LT goals rather than ST performance

for individual:
1. return: variable objectives
may conflict internally and change over time
return maybe titled toward income

  1. risk: difficult to determine
    subject to behavioral influences
    smaller asset based increases sensitivity of risk
  2. constraint
  3. liquidity
    may be variable and subject to period shortfall
  4. time horizon:
    long >10 years
    but short than pension plan
  5. tax
    fully taxable with some tax advantaged and tax-exempt accounts
  6. legal/regulatory
    ordinarily very few
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25
Q

portfolio traditional approach

A
  1. identify asset clases
  2. developed CME
  3. determine portfolio allocation
  4. asset constraint
  5. implement the portfolio
  6. determine asset allocation
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26
Q

goal-based

optimized with stated max level of volatility of % of success

A

adv: it may be easier for clients to express their risk tolerance on a goal -specific basis rather than at the overall portfolio level

disadv:
the combination of goal portfolio allocations may not be sufficient

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27
Q

Ethic consideration

A

fiduciary duty and suitability
know your customer
confidentiality
conflict of interest

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28
Q

private client segments

A

-robo-advisor
automated advisors, lower fees use questionnaire

-mass affluent segment asset levels between $250,000 and $1 million
serves clients who are focused on building their portfolios and want help with financial planning needs.

greater technology, no customization

  • high net worth client
    smaller # of customer, tailored investment solution, tax planning, estate planing, contain sophisticated strategy

asset levels between $1 million and $10 million and can provide a team of specialized advisers that supports more customized strategies for more sophisticated investments with longer time horizons, greater risk, and less liquidity.

  • ultra high net work segment:
    low client to manager ratio
    luxury service
    multi-genration family member

asset levels over $50 million for clients with multi-generational time horizons and provides a wider range of services for complex tax situations, estate planning, bill payment, concierge services, travel planning, and advice on acquiring high-end assets.

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29
Q

tax aware investment model are valuable:

A
  1. tax codes change over time

can be applied in a broad range of circumstance representing diff. taxing justifications, asset classes, and account types

  1. can provide a framework with which advisor can better communicate the impact to taxes of portfolio returns to private clients and develop techniques to improve their after tax performance
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30
Q

tax structure

A

tax on:
income
wealth-based
consumption

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31
Q

common progressive regime:

A

progressive tax rates for ordinary income,
favorable treatment in interest, dividend, capital gain

most common

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32
Q

heavy dividend tax regimes

A

progressive tax system for ordinary income and favorable treatment for some int. capital gains but dividends at ordinary rates

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33
Q

heavy capital gain tax regimes

A

favorite treatment for interest dividend

progressive tax system for ordinary income

capital gains tax at ordinary rates

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34
Q

heavy interest tax regime

A

interest income at ordinary rate

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35
Q

light capital gain tax regime

A

second most common observed
progressive for income, int, dividend,
fav or capital gains

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36
Q

flat and light regime

favorable for int, dividend and capital gains

A

flat tax system and treats interest, dividend and capital gains favorably

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37
Q

flat and heavy regime

favorite for interest income

A

flat tax system for ordinary income
dividends and capital gains

no favorable treatment for dividend and capital gains
but favorable treatment for interest income

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38
Q

TDA tax deferred account

Deferred tax for capital gain is: (1+r)^n(1-tcg)+tcg
Deferred tax account is :(1+r)^n(1-T)

A

defers taxation on investment return
may permit a deduction for contribution
may occasionally permit tax free distribution

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39
Q

single tax environment FV

A

= (1+r(1-rt))^n

tax drag: gain lost to taxes = gain without tax - gain after taxes

tax drag % = tax drag $/gaini without taxes

tax drag% > tax rates due to compounding

R & T increase both tax drag and tax drag %

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40
Q

deferred capital gains (deferred until realized)

FV

A

FVcg = (1+r)^n *( 1-tcg)+tcg

no lost compounding of return
tax drag $ increase with time horizon and rate of return

if B=0( non initial unrealized g/l)
tax drag %= tax rate

if b <1 (initial unrealized gain) tax drag % > tax rate
if b >1 (unrealized loss) tax drag% < tax rate

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41
Q

wealth based taxes

A

applied annually to a specific capital base

FV =[ (1+r)(1-tw)]^n

inv. horizon increase lead to tax drag % $ both increase
inv. horizon decrease lead to tax % decrease, $ increase

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42
Q

blended taxing environment
interest
dividend
capital gains

weighed avg realized tax rate (WARTR)

A

WARTR = %w%R

Riti +Rdtd+Rcgtcg

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43
Q

return after realized taxes r*=

A

r(1-awrtr)
r* = r(1 – %w%t)
overstates true after-tax return because there’s no unrealized gain an a potential future tax liability to be paid on this gain.

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44
Q

Effective capital gains tax T*

TAE

A

TAE T* =
Tcg(1- sum of %weight)
/(1-wartr)
= 1- R*/R

WARTR = sum of %w%t

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45
Q

FV* taxbable =
b= basis cost/ current investment value
there already capital appreciation

FVIFTaxable = (1 + r)^n(1 – T) + T* – (1 – B)tcg, B = 1

A

(1 + r)^n(1 – T) + T* – (1 – B)tcg, B = 1

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46
Q

accrual equivalent tax Rate=

A

r(1-TAE)

initial investment value * (1+RAE)^n = AFTER TAX investment value

  • used to measure tax efficiency of different asset class or pm styles
  • illustrates to clients the tax impact of lengthening the average holding periods of stocks they own
  • assess the impact of futures tax law changes
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47
Q

taxable account

gove’t bear part of investment risk

A

after tax income invested

taxed return

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48
Q

TDA deferred account

A

before tax income
taxed when withdraw
FV = (1+r)^n(1-tn)

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49
Q

TEA exempt account

inter bear all investment risk

A

has no future tax liabilities

=(1+r)^n

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50
Q

tax loss harvesting

A

= loss * t

realize a loss to offset gain

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51
Q

mean- variance optimization

A

use accrual equivalent after-tax return

and af tax std

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52
Q

estate planing in a global context

A
  1. can be applied in a variety of jurisdiction
  2. provides an international perspective that advisors can use to counsel clients with a multi-jurisdiction foot print
  3. provides a framework advisors can use to communicate tax and succession planning consideration to private clients to develop technique to address the need and objectives of such clients
  4. inheritance laws and tax codes in many jurisdictions are fluid over time
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53
Q

Estate planning

A

process of preparing for the disposition of one’s estate upon death and during one’s lifetime

Will: outlines the rights others sill have over one’s party after death

probate:
legal process to confirm the validity of the will so that executors hires and other interest parties can rely on it authenticity

intestate: a decedent outline a valid will or with a will that does not dispose to their property

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54
Q

civil law

roman low

A

developed primary through legislative status or executive action

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55
Q

common law

Britain

A

developed primary through decisions of the courts

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56
Q

forced heirship rule

A
  • children have the right to a fixed share
  • may reduce a forced heirship claim by gifting of denoting assets
  • may move asset into a offshore trust governed by a different domicile to avoid forced heirship rule
  • clawback provisions bring such lifetime gifts back into the estate to calculate the child’s share
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57
Q

common property regimes

A

each spouse has an indivisible 1/2 interest in income earned during marriage

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58
Q

separate property regime

A

prevalent in civil law countries, each spouse is able to own and control property as an individual which enables each to dispose of property as they wish, subject to spouse’s other rights

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59
Q

estimate core capital with mortality table

A
  • incorporate inflation effet over long-time horizon

- forecast nominal speeding need and discount to pv using nominal rates

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60
Q

survival prob= p( joint survival) =

use mortality table
subject to longevity risk

to mitigate, can incorporate safety reserve

A

p(husband survives) +p(wife survives)

-p(h)*p(W)

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61
Q

pv(spending needs) =

A

sum or p(survival)*spending /(1+r)^n

r= 1+r/1+g

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62
Q

safety reserve

A
  1. provide a capital cushion if capital produce s sequence of unusually poor return that jeopardize the sustainability of the planned spending program
  2. allows the 1st generation to increase their spending beyond that explicit articulated in the spending program
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63
Q

est. core capital with monte carlo analysis

A
  • incorporate recurring spending needs, irregular liquidity needs, taxes, inflation, and other factors in to the analysis
  • exp(r) derived from the market expectations of the assets

capture the interaction of distribution and the sequence of returns, a form of path dependency

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64
Q

probability or ruin

A

reaching a zero portfolio value
based on different start date for retirement and distribution %.

delay retirement or lowering distribution % make it less likely the portfolio can be exhausted.

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65
Q

transferring excess capital

lifetime gifts and testamentary bequests

A

gifting now likely give up control and cannot be revoked if circumstances change with tax issues

relative value >1 tax perspective is favorable to gift

relative value <1 bequest if more favorable 遗嘱

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66
Q

Relative value RV=

RV = FVg/FVb

A

FV after tax to the receiver if gifted now

/ fv after tax to the receiver if bequested

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67
Q

tax free gift

A

RV = FVg/FVb
=[1+rg(1-tig)]^n
/[1+rb(1-tib)]^n (1-tb)

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68
Q

taxable gifts (tax paid by receiver)

FVg changes

A

RV=
[1+rg(1-tig)]^n * (1-tg)
/[1+re(1-tie)]^n (1-te)

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69
Q

taxable gifts (tax paid by giver)

FVg changes

A

RV=
[1+rg(1-tig)]^n * (1-tg + TgTe)
/[1+re(1-tie)]^n (1-te)

TgTe = tax benefit from reducing the value of the taxable estate

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70
Q

location of the gift tax liability

A
  • a cross broader gift could return in both the donor and the recipient being taxes in their home counters
  • if the tax liabilities is imposed on the donor’s taxable estate rather than on the recipient, the tax benefit of the lifetime gift vs. the bequest increase

more attractive when the gift tax is paid by the donor

if tax rates are the same, gifting reducing the size of the taxable estate which is better to gift

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71
Q

Generation skipping

benefit from skipping by 1/(1-t)

A

1st to 2rd generation in 15 year tax =40%
3rd in 30 years

after tax return =5% on asset

FVno skipping 
= pv(
(1.05)^15 *(1-0.4)
* (1.05)^30)(1-0.4)) 
=pv(3.2344)

FV skipping:
=pv(
(1.05)^45(1-0.4))
=pv(5.3910)

by 1/(1-t) = 1/(1-0.4)=1.6667

5.3910/3.2344 = 1.6667

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72
Q

Spousal exemptions

A

most jurisdiction with estate or inheritance also allow dependent to make bequest and gift to their spouses without transfer tax liability

it’s advisable to transfer the exclusion amount to someone other than the spouse, child tax free

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73
Q

Deemed disposition

A

is used when a person is considered to have disposed of a property, even though a sale did not take place.

74
Q

charitable contribution transfer

A
  1. most charitable donations are not subject to a gift transfer tax
  2. most jurisdictions permits income tax deductions for charitable donations
75
Q

RV charitable gift =

FV charitable gift /FV bequest

A

=[ (1+rg)^n +Tincome ] * (1+re(1-tincome)]^n *(1-Testate)
/
[1+re(1-tincome)]^n * (1-testate)

76
Q

valuation discounts

A

liquidity, minority discounts can reduce the value of wealth transfer and the associated taxes, individuals will utilize them by transferring interests in a family business

77
Q

estate planning tools

A
  • gratuitous transfer are often implemented through structures that either maximize for benefit produce a non-tax benefit, or both

trust
foundations
life insurance
and companies

78
Q

trusts

A

arrangement created by settlor/grantor who transfer assets to a trustee

trustee is responsible for reporting and paying taxes on income

reason to use trust:
0. protection of asset within the trust from claims outside the family.

  1. avoid disputes within the family
  2. provide privacy protection without publicity associated with probate.
  3. permit nomination of a trustee of choosing to manage the insurance benefit.
  4. trustee may be given discretionary power to alter the timing of amount of payment if situations changes or needs change over time
79
Q

revocable trust

A

settlor retains the right to revoke the trust relationship and regain title to the trust asset

80
Q

irrevocable trust

A

the settler has no ability to revoke the trust relationship, provide greater asset protection from bondholder claims

81
Q

Fixed trust

A

occur at certain time or in certain amount

82
Q

discretionary trust

asset protection from claims against the beneficiaries

A

trustee to determine whether and how much to distribute based on his general welfare and in the sole and uncontrolled discretion of he trustee

83
Q

control

A

motivation for using trust

1. to make resources available to a beneficiary without yielding complete control of those resources to them

84
Q

Foundation

A

Legal entity

set up to hold assets to promote education or for philanthropy

85
Q

life insurance

perfect hedge against the loss of human capital in the event of death,

A

policy holder transfers assets (premium) to an insurer who has a contractual obligation to pay death benefit proceeds to the beneficiary names in the policy

  • death benefit proceeds paid to life insurance are tax except.
  • offer asset protection in combination with a trust
  • offer liquidity to pay estate taxes upon death
  • payment of premium reduce value of estate, and lower future estate tax
86
Q

Companies and controlled foreign corporations CFC

A

A company locate outside a taxpayer’s home country in which the taxpayer has a controlling interest as defined under the home country law

  • tax on earnings can be deferred until either the earnings are actually distributed to shareholders or the company is sold or shares otherwise disposed

CFC rule trigger:
if taxpayer 50% of feign company’s share

87
Q

Deemed distribution

A

CFC may tax shareholders of a CFC on the company’s earnings as if the earning were distributed to shareholders even through no distribution has been made.

88
Q

cross-boarder estate planing

A

the hague conference on private international law is inter gov’t organization that works toward the convergence of private international law.

purpose:
to simplify or standardize processes and facilitate international trade.

89
Q

The Hague conference of the conflict law

A

relating to the form of testamentary dispositions address varying form of will issue

39 countries excluding US

90
Q

A will is valid if it’s consistent with the international law associate with

A
  • the place the will was made
  • the nationality, domicile, or habitual residence of the testator on
    the location of immovable assets covered under the wil
91
Q

tax system

A

a country that taxes income sources within its border is said to impose source jurisidication also referred to as a territorial tax system

92
Q

taxation of income

A

residence jurisdiction, applies to worldwide income

93
Q

taxation of wealth

under source-jurisdiction,

A

transfer taxes are livedor assets location within or transferred within a country whether by citizen or foreign

94
Q

under residence jurisdication

A

citizens and residents pay transfer taxes regardless of the worldwide location of the assets

95
Q

exit taxation

A

tax on individual giving up their citizenship or residency

96
Q

Deem disposition

A

exist tax amount to a tax on unrealized gains accrued on assets leaving the taxing jurisdiction

may also include an income tax on income earned over a fixed period after expatriation called a “shadow period”

97
Q

double taxation

A

interaction of country tax systems can result in tax conflicts in which 2 countries claim to have taxing authority over the same income or assets

Intended to facilitate internet trade, and investment by eliminate double taxation

98
Q

residence-residence conflict

A

2 countires may claim residence of the same individual, subjecting the individual’s worldwide income to taxation by both countries

99
Q

source-source conflict

A

2 countries may claim source jurisdiction of the same asset

100
Q

residence -source conflict

A

an individual might be subject to residence jurisdiction and receive income on assets in a foreign country with source jurisdiction

  • most common, most difficult to avoid
    US citizen owning AU situated real estate would be subjected to US income tax and AU income tax on rental income
101
Q

proving tax credit provision

A

provide its taxpayer relief from residence-source conflicts using

credit method (complete reduction)
exemption method  (complete reduction)
deduction method  (partial reduction)
102
Q

Credit method

Credit method = max ( T residence, T source)

A

the residence country reduces its taxpayer’s domestic tax liability for taxes paid to a foreign country exercising source jurisdiction

Credit method = max ( T residence, T source)

103
Q

Exemption Method

Exemption method = T source

A

the residence country imposes no tax on foreign source income by providing taxpayers with an exemption, which in effect, eliminates the residence-source conflict by having only one jurisdiction impose tax.

Exemption method = T source

104
Q

Deduction Method

partial

T deduction method =Tresident + T source - Ts*Tr

A

the residence country allows tax payers to reduce their taxable income by the amount of taxes paid to foreign government in respect of foreign -source income.

105
Q

OECD

solves both residence-source conflict and Residence-resident conflict

A

organization for Econ. co-operation and development model treaty section eh exemption and credit method to resolve residence-source conflict.

106
Q

tax avoidance / minimization

A

developing straggles that can form to both the spirt and the better of the tax codes of the jurisdiction with tax authority

107
Q

tax evasion

A

the practice of circumventing/avoid tax obligations by illegal means such as mis-resporting or not reporting revenant information to tax authorities

108
Q

tax evasion

A

the practice of circumventing/avoid tax obligations by illegal means such as mis-reporting or not reporting revenant information to tax authorities

109
Q

concentrated single asset positions

A

public-traded single stock positions
private held business including family owned business
investment real estate

110
Q

inv. risk of concentrated positions

A
  1. systematic risk
    that cannot be eliminated by holding a well-diversified portfolio
    CAPM
    macro economies
  2. company-specific risk
    non-systematics or idiosyncratic risk that is specific to a particular company’s operations, reputations, and business environment
  3. property - specific risk
    nonsystematic risk that is specific to owning a particular piece of real estate
111
Q

a single asset portfolio has more extreme positive skew for 2 reasons:

A
  1. a higher average ending value reflecting the benefit of tax deferred
  2. a much higher of probability of total loss due to bankruptcy of a single asset
112
Q

general principal of managing concentrated single-asset positions

objectives (3)

A
  1. reduce risk of wealth concentration
  2. generate liquidity to diversify and satisfy the cash flow need
  3. Optimize the tax efficiency by enter structuring transaction involving concentrated position so as not to trigger an immediate taxable event and if a taxable event will be triggered, structuring the transaction in a manner that minimize the tax the owner will incur.
113
Q

client objective and concerns on concentrated position

A
  1. mandated to hold shares
  2. maintain effective voting rights
  3. enhance current income
  4. necessary for the successful operations
  5. significant taxable capital gain
  6. concentrated positions are generally liquid
  7. psychological considerations
114
Q

consideration affection an concentrated positions

A

tax consequences of an outright sale
- deferring or eliminating in CGT is typically a primary objective for investor who own a concentrated position

liquidty

115
Q

institutional & capital maket constraints

A

margin-lending rules:

determine how much a bank or brokerage from lend again securities positions that their customers own

-Rule based system, the amount can be borrowed against a security that the investor owns will depend on strict rules deciding with the use of the load proceeds

  • Risk based
    portfolio margins provides additional flexibility to achieve the desired economic and tax results
116
Q

Prepaid variable forward

A

collar & loan combined with a single instrument
secured lending

  • off-balance sheet debt
  • not subject to margin rules

A variable prepaid forward contract is a strategy used by stockholders to cash in some or all of their shares while deferring the taxes owed on the capital gains.

The sale is not finalized. That’s an advantage for holders of stock options with a later exercise date.

117
Q

security laws and regulation

A

may define the owner as an “insider” who is presumed to have moderate nonpublic information and impose restrictions, regulations, and reporting requirements on the position.

118
Q

Contractual restriction and employers mandates

A

may impose restrictions (such as minimum holding period or black out period when sales may not be made) bond those of securities law and regulations

119
Q

capital market limitation

A

borrow and shorting the underlying asset is often required for the dealer to hedge their risk.

this is prohibited in some markets without sufficient price history and liquidity in the underlying instruments, monetization techniques may be unavailable.

120
Q

Goal-based planing is the concentrated position decision making process

A

to overcome psychological bias

121
Q

aspiration risk bucket

goal: the opportunity to increase wealth substantially to have the possibility of moving upward in the wealth spectrum

A

p/e

real estate

122
Q

market risk bucket

goal: maintain the current living standard

A

public equities and bonds

123
Q

personal rick bucket

goal: protection from poverty or a dramatic decrease in life style

A

T-bill
CD
property

124
Q

asset location and wealth transfer

A

asset location determines the method of taxation that will apply

can used together with gifting strategy to minimize transfer taxes with respect to concentrated positions.

125
Q

wealth transfer before significant appreciation

involve estate planing and gifting to dispose of excess wealth

early transfer in the ownership life of a concern trade position often enables the owner to shift future wealth with little or no transfer tax consequences.

the specific strategies used depend on the tax law of the country and the owner’s situation

A

key consideration:

  1. advisor can have the greater impact by working with clients before significant unrealized gains occur. If there are no unrealized gains, there are generally no financial limitations on disposing of the concentrated position.
  2. donating assets with unrealized gains to charity is generally tax-free even if there are gains
  3. LIMITED partnership
    an estate tax freeze is a strategy to transfer future appreciation and tax liability to future generation. This strategy usually involve a partnership or corp. structure.

gift tax due on the value of asset when the transfer is made.

The asset will be exempt from future estate and gift taxes in the givers estate

126
Q

technique to use after significant appreciation has occurred to minimize transfer taxes:

A
  • family limited partnership
    Parent generally retain partnership interest and therefore retain control of the partnership and the concentrated position within it.
    the parents gift the limited partnership interest to their child.
  • limited partnership interest is valued for transfer tax purpose, value generally < a proportionate value of the assets held in the partnership.

This arises because:

  1. lack of marketability
  2. general partner retrain control, limited partners’ non-controlling interest is worth less because he has very little ability to influence against of the partnership and the underlying assets
127
Q

Tax savy

A

if concentrated position appreciate further b/w date of gift and gift of parent’s death

128
Q

5 step in concentrated wealth decision making

A
  1. identify and establish objectives and constrains
  2. identify tools/strategies that can satisfy these objective
  3. compare tax advantages and disadvantages
  4. compare non-tax advantages and disadvantages
  5. formulate and document an overall strategy
129
Q

3 techniques used to manage concentrated positions

A
  1. sell the asset
    outright sale will trigger a tax liabiltiy and loss of control
2. monetization strategy 
borrow against its value and use the load proceeds to accomplish client objective 
- margin loans
- fixed and floating rate debt
- recourse and non-recourse debt
- loans embedded with a derivatives 
- short sale against the box
- restricted stock sale
- public capital market based transaction 
  1. hedge the asset value
    often done using derivatives to limit downside risk
  • exchange traded options
  • OTC derivatives (options, forwards, swaps)

drawback:

  1. expensive premium if purchase a lot of contract
  2. counterpart risk for OTC derivatives
130
Q

OTC

A

create counterpart credit risk

provide flexibility in setting the specific terms of instrument

131
Q

exchange traded instruments

A
  1. facilitate closing the transaction early by entering an offsetting transaction
  2. provide price disclosure because transaction prices are publicly reported
  3. provide more transparent fees and transaction costs because it’s easier for a dealer to embed transaction costs in complex OTC derivatives
132
Q

monetization strategies

investors holding a concentrated position:

  1. hedging against a fall in price of a stock
  2. defer capital gains tax
  3. generate liquidity (cash )
  • hedge remove a large portion of risk
  • borrow against the hedge position
    a high LTV can be achieved as the stock position is hedged
  • borrowing is quite inexpensive because the income generate on the hedge position offset cost of borrowing
A
  • transform of a concentrated position in cash
  • transact that are distend to empower an investor to receive cash for their stock position through a manner other than an outright sale in a way that avoid trigger taxable event.
133
Q

equity monetization tool set 4
1. short sale against the box

-least expensive technique for hedge monetize and potentially defer the capital gains tax on a concentrated position.

A
  • hedging technique require borrowing and shorting the company stock.

investor shorting a security that is held long

134
Q

equity monetization tool set 4
2. total return equity swap

stock position is completely hedged, monetization with a very high LTV ratio should be possible

A

contract for a series of exchange of the total return on a specific asset in return for specified fixed or floating payment.

135
Q

equity monetization tool set 4
3. forward conversion with option

partially hedge, monetization with a very high LTV ratio should be possible

A

involves the construction of a synthetic short forward position against the asset held long
payoff of a short forward position is identical to
= long put + short call

136
Q

equity monetization tool set 4
4. equity forward sale contract

perfectly hedged, monetization with a very high LTV ratio should be possible

A

private contract for the forward sale of an equity position

137
Q

equity monetization tool set 4
4. equity forward sale contract

perfectly hedged, monetization with a very high LTV ratio should be possible

A

private contract for the forward sale of an equity position

138
Q

tax treatment of equity monetization strategy

A
  • can eliminate concentrated risk and generate about the same amount of cash that would be generated by an outright sale
139
Q

tax treatment of equity monetization strategy

A
  • can eliminate concentrated risk and generate about the same amount of cash that would be generated by an outright sale

-yield enhancement with covered call
drawback of covered call: limited upside and no downside protection

140
Q

tax-optimized equity strategies

A
  1. index tracking with active tax mgmt

tax on div > cgt, invest in low dividend yield stocks

  1. completeness portfolio
    if have a concentrated position in auto stock, could invest in other stocks with low correlation of auto stocks

cross hedge
if has a concerned option in JetBlue but not available puts on JetBlue, could choose to long a put on comparable company such as Delta

or short an index with high correlation .

  1. buy puts on a proxy asset in that the put and stock are different types of asset

-Exchange funds involve doing other individual who have concentrated position on other companies with each investor contributing their shares to the funds, all investors now own a portfolio to the resulting diversified portfolio.
No tax liability are realized on the initial contribution of shares

Lock in unrealized gains: hedging

  1. purchase of puts short puts
    - lock in floor price
    - retain unlimited upside potential
    - defer the capital gains ax
  2. collar, cashless collar
    - hedge against a decline in the price
    - retain a certain degree os upside potential
    - defer the capital gains tax while avoiding any out of pocket expenditures
  3. prepaid variable forward
141
Q

issue: mismatch in character

A

when the gain or loss in the concentrated position and the offset loss or gain in hedge are subject to different tax treatment

142
Q

managing the risk of private business equity

A
  • valuation level of target company
  • tax rate applicable to a particular exist strategy
  • condition of credit market
  • level of interest rates
  • amount of buying power
  • currency valuation
143
Q

financial tool set for managing private business equity

A

allow company owners to generate full or partial liquidity

exist plan
1. sale to 3rd party investor
strategic buyer (trigger a capital gains tax liability)
: take a buy and hold perspective and generally offer higher price + stock synergies

Financial buyer: offer a PE fund planning to restructure the business, add value, resell,

purchase more mature, establish businesses and offer a lower price than a strategic buyer

  1. sale to mgmt MBO
  2. recapitalization
    used for establish but les mature companies
    multi-strategy stray that owner transfer a portion os stock to a PE for cash and retain a minority ownership, interest

Later, pE will acquire the rest of the interest
- provide liquidity, reduce risk and retain incentive but will lose control of the firm

  1. IPO
  2. use diff. sources of capital
    - senior debt
    - mezzanie debt
    0equities
  3. divesture
    if a business owner is not yet ready to retire and wish to continue run the business but would like to generate some liquidity now, he/she may consider selling a certain line of business or closing a division
  4. personal line of credit
    the owner arranges a persona loan secured by his/her shares in the private company, no immediate taxable event if structured properly
  5. ESOP
    selling some or all of the company shares to certain types of pension plan
144
Q

managing the risk of investment real estate

A

factors affect value:

  • current valuation vs. historical level & future expectations
  • tax rate applicable to a particular property and transaction
  • condition of the credit market and lending conditions
  • level of interest rates
145
Q

monetization strategies for real estate owners

A

mortgage financial
sale and lease back
charitable donation

146
Q

leveraged recapitalization

A

a strategy involves retooling a company’s B/S in partnership with a PE firm.

allow the owner to have 2 liquidity event:
1 up-front and a second typically within 3-5 year time frame when the PE firm cashes out the investment.

the pe firm invest equity capital and arranges debt with senior or subordinated lender. The owner transfer stock for cash and an ownership interest in the newly capitalized entity. This allow the owner to monetize a significant upside potential with the remming ownership.

from the tax perspective, owner is taxes currently on the cash received and typically receive a tax deferral o the stock rolled over into the new entity

disadvantage:
1. Financial buyer price paid not as high as strategic buyer
2. owner lose control of the company

147
Q

risk management for individual

life cycle finance

A

helping investor achieve their goal, including an adequate retirement income, by taking a holistic view of the individual’s financial situation

recognize that as investors age, the fundamental active of their total wealth evolves as do the risks that they face.

148
Q

Economic net worth

A

= net worth from traditional b/s
+ pv(futures earning)
- pv(consumption goal)
-pv(bequets)

149
Q

risk avoidance

A

choose action to avoid the chance of the loss occurring, avoiding the risk altogether

150
Q

risk reduction

high frequency low loss

A

choose action that reduce the likelihood or amount of loss

151
Q

risk transfer

buying insurance
infrequently high loss

A

use insurance products to transfer the loss to others

152
Q

risk retention

infrequently low loss

A

maintain sufficient assets to absorb the loss

153
Q

earnings risk

disability income insurance

A

insure with disability insurance

the risk of getting unemployed, disabled, or unable to work affecting both human capital and financial capital.

154
Q

premature death risk

A

insure with life insurance, the risk of the death of an individual earlier than anticipated

155
Q

property risk

A

insure with property insurance

it relates to the prob. that a person’s property is damaged, destroyed, stolen or lost

156
Q

liability risk

liability insurance

A

insure with liability insurance
the possibility that an individual maybe held legal liable of the financial costs associated with property damaged as physical injury

157
Q

health risk

A

insure with health insurance

risk and implications associated with illness and injury

158
Q

life insurance

A

protects against the lost of human capital for those who depend on an individual’s future earnings

  • provide hedge against protective death
  • estate planing tool, provide immediate liquidity to a beneficiary
  • tax-sheltered saving instrument
159
Q

temporary life insurance

term life

A

that covers for a certain period of time specified at purchase. Cost is lower than permanent life insurance.

160
Q

permanent life insurance

A
  • whole life insurance /life time coverage (fixed premium)
  • universal life insurance
    a form of permanent insurance that can remain in force until death and typically has more options for investing the cash value than do whole life policies.

provide more options for investing the cash value

161
Q

key consideration in policy of life insurance

A
  1. mortality expectation
    generalize mortality table adjusted to additional factor

underwriting process reduces the likelihood of adverse selection (Adverse selection is when sellers have information that buyers do not have, or vice versa)

higher than average risk are more likely to apply for life insurance

  1. net premium/ gross premium/ discount rate
    representing an assumption of insurance company’s return on portfolio is expected to the cash flow
    - discount value of futures death benefit
    gross premium: adds a load to net
  2. loading
    covers operating cost and expense for underlying the policy
162
Q

whole life policy offer advantage of level premium and an accumulation of cash value within the policy that:

A
  1. can withdrawn by the policy owner when the policy matures or when he/she terminate the policy
  2. can be borrowed as a loan while keeping the policy in force
    - premium stays constant
    - face value stays the same
    - cash value increase
    - insurance value decrease

non-forfeiture clause

163
Q

policy reserve

A

a liability on the insurance company’s B/S

= pv of future benefits- pv of future net premiums

164
Q

net payment cost index

A

assumes policy will be surrendered at the end of the period and that the policy owner will receive the projected cash value

= fv of premium (annuity due, BOE)
- fv of dividend (ordinary income EOD)
= LUMP SUM
求pmt

index value = pmt / 100

165
Q

Surrender cost index

A

fv of premium (bod)
- fv of dividend (eod)
- cash value (given)
= insurance cost

求pmt, pmt/100 = index value

the lower the index value, the better the value

166
Q

primary purpose of life insurance

A

replace the pv of future earning

  • immediate financial expense
  • legal goals
167
Q

annuity

A

pay income as long as the owner is alive
- one-time premium payment in exchange for fixed payments received for the life of the amount

the initial investment/ premium is not returned at the end
payment are the interest and a return of principal

168
Q

deferred annuity

variable annuity

A

the annual receipts start at a deferred future date

allow the owner to select from a list of investment options

169
Q

Deferred fixed insurance

A

pay a fixed benefit for life that starts at a defined future date
- the longer the delay b/w initial premium paid and start of pmt received, all else the same, the lower cost of the annuity as the company can invest and increase the funds available before making payment on annuity

170
Q

advanced life deferred annuity

A

relative low cost to hedge the longevity risk

  • require immediate premium pay out at purchase
  • payment are fixed, delay period is long
    age 80 or 85 after

low premium reflect:

  1. long delay before payout begin allow the company to grow asset
  2. the period of payment will be shorter as the life expectancy the older annuitant will be shortened when payment begin
  3. a greater protection of the annuitants will die before they receive any payments
171
Q

factor favor use annuity over self-insurance:

A
  • a longer than average life expectancy
  • a desire for lifetime income
  • conservative investors ( high risk aversion)
  • an absence of other guaranteed income sources such as pensions
  • less desire to leave an estate for the benefit of others
172
Q

adjusted discount rate =

A

(1+r) / (1+g)

173
Q

Joint life annuity

A

2 or more individual
husband and wife
receive pmt until all beneficiaries die

174
Q

fixed annuity

A

benefit:

  1. known and constant income stream
  2. lower fee cost
  3. investment performance risk borne by annuity provider

disadvantage:

  1. rate of return fixed at once
  2. inflation erodes purchasing power of cash flow
  3. no early access to funds once established
175
Q

variable annuity

A

benefit:

  1. may better adjust payout for inflation over time
  2. performance adjusts to current market environment
  3. growth within annuity product tax-deferred
  4. possible to reclaim some asset early

disadvantage:
1. payout uncertain
2. performance risk borne by annuitant
3. higher fee cost

176
Q

Both the liability-relative and goals-based approaches consider assets relative to liabilities. The main difference between the two approaches is that

A

the liability-relative approaches focus on institutional investor liabilities

while the goals-based approaches focus on individual investor liabilities.

177
Q

minimum entitlement to estate taxes

A

= max (1/2 of increase of total estate during marriage under community property, 1/3 under forced heirship)

178
Q

avoid probate

A

joint ownership
living trusts
retirement plan
life insurance strategies

179
Q

reduce impact of forced heirship

A

moving assets into an offshore trust

gifting or donating

purchasing life insurance by move assets outside of realm of forced heirship provisions.

180
Q

conflict of taxation

A

residence-residence

source-source conflict

residence source

181
Q

the income yield is higher when expected longevity is shorter;

A

therefore, the income yield will be higher for an older person.