Gain crystallised at 0% on the move into the policy, while UAE resident
Figures marked illustrative are worked examples on the stated assumptions, not projections or guarantees. · For professional advisers and their clients
01
The client
Who was the client?
At a glance
The client: Ingrid, 54, Swedish national, Dubai resident since 2011, married with two adult children
The challenge: US$8m of US shares held directly, exposed to two countries' tax regimes now, and one more in the future
The structure: a Bermuda based PPLI, funded in specie while UAE resident, at 0% tax on her gain
Placed in the policy while she was UAE resident,at 0% on a US$5.26m gain.
The UAE does not tax individuals on capital gains. The same move after a return to Sweden would have been taxed at 30%.
US investments
No 30% US withholding on dividends and no US estate tax exposure on the portfolio
UAE
The policy pays her chosen beneficiaries under its own terms, alongside a registered Will
Sweden
If she returns, a yearly yield tax on policy value replaces 30% tax on dividends and gains
02
The three jurisdictions
What was at stake, and what changed
Three countries reach this portfolio: the one where the shares sit, the one where she lives, and the one she may go back to. Each is answered separately.
United States
Where the assets sit
Exposure without PPLI
×US estate tax on US shares above a US$60,000 threshold, at rates reaching 40%: about US$3.13m on US$8m
×30% withholding on every US dividend. There is no US income tax treaty with the UAE, and her Swedish passport does not change that
Inside the structure
✓The insurer owns the shares, and a policy on her life is not US property for estate tax
✓The insurer's §953(d) election means dividends arrive without the 30% withholding and are reinvested in full
✓Moving the shares in was a sale: 0% tax on the US$5.26m gain
United Arab Emirates
Where she lives today
Exposure without PPLI
×With no registered Will, UAE civil law divides her UAE estate: half to Lars, half shared equally by the children
×Heirs may ask for Swedish law to apply instead, and banks typically freeze accounts until a court order
Inside the structure
✓The policy pays the beneficiaries Ingrid named, in the shares she chose, under the policy terms
✓A registered DIFC Will now covers her other UAE assets
Sweden
Where she may return
Exposure if she returns
×30% tax each year on dividends and on gains when realised; US dividends still lose 15% under the US–Sweden treaty
×Moving the shares into a Swedish wrapper after the move counts as a sale: 30% on the US$5.26m gain, about US$1.58m
Inside the structure
✓Taxed as a foreign kapitalförsäkring: a yearly yield tax on policy value, 1.065% for 2026
✓Tax is on value, not actual gains, so it is predictable, though still taxed annually. Withdrawals are not taxed
Illustrative
US$3.13m
US estate tax exposure on US$8m held directly
30% → 0%
US withholding on dividends, before and after
1.065%
Swedish yield tax on policy value for 2026, if she returns
Why the timing mattered
The shares went into the policy while she was UAE resident, so the US$5.26m gain was crystallised at 0%. The same transfer after a return to Sweden would have been a sale taxed at 30%, about US$1.58m. The order of events did the work.
03
The outcome
Holding the shares directly, or inside the policy
The same US$8m, before and after. Every figure is on the assumptions in the note beneath the table.
Holding the shares directlyInside the Bermuda based PPLI
US estate tax on the portfolio
DirectlyAbout US$3.13m on death
Inside the PPLINo exposure on the portfolio
US withholding on dividends
Directly30%, about US$24,000 a year
Inside the PPLIDoes not apply
Succession in the UAE
DirectlyDefault civil split without a registered Will; accounts frozen pending a court order
Inside the PPLIPolicy pays named beneficiaries; DIFC Will covers other UAE assets
Swedish tax after a return
Directly30% on dividends and realised gains; 15% US withholding continues
Inside the PPLIYearly yield tax on value: 1.065% for 2026
Tax on the US$5.26m gain
Directly30% if moved or sold after a return to Sweden: about US$1.58m
Inside the PPLI0%: crystallised on the move while she was UAE resident
US figures illustrative: US$8m of US-situs shares, IRC §2001(c) rates less the US$13,000 credit; withholding at a 1.0% dividend yield. Gain of US$5.26m crystallised on the move into the policy: the UAE does not tax individuals on capital gains, and the Swedish figure is 30% of the gain, before currency effects. Swedish rate for 2026 only. Policy charges apply and reduce returns. The policy's assets are held in a ring fenced segregated account under Bermuda's Segregated Accounts Companies Act 2000.
Figure 1
Where the US$8m sits, before and after
The bank and the investment manager did not change. The owner of the shares did.
Not US property for estate tax; §953(d) election, no withholding
held at
Bank and investment manager
Unchanged
Figure 1. The bank and the investment manager are unchanged. The insurer became the legal owner of the shares when they were transferred in as the premium.
0%
Tax on the US$5.26m gain, crystallised while UAE resident
US$24,000
A year of US withholding that no longer applies, at a 1.0% yield
1
Registered DIFC Will now covering her other UAE assets
The bank and the manager stayed.The owner of the shares changed.
That one change answered the US, the UAE and a possible return to Sweden.
Next step
Have an expatriate clientwith US shares?
A 20-minute call on your client's residence, US exposure and objectives, and whether a Bermuda based PPLI is worth pursuing. The full case study, with sources and the UAE and Sweden notes, is available on request.
Carlton Crabbe is the Founder and CEO of Capital for Life, an international life insurance advisory specialising in Indexed Universal Life and Private Placement Life Insurance for high net worth and ultra high net worth families, entrepreneurs and their advisers. With close to 30 years of specialist experience, and prior regulated roles at Barclays Private Bank and Grant Thornton, he designs cross-border IUL and PPLI structures for protection, liquidity and global estate planning across the UAE, UK, Europe, Africa, Asia and Australia.
Capital for Life has advised (U)HNW and corporate clients from Google, Red Bull, BlackRock, L’Oréal, private equity executives, the UK government, hedge fund managers, billionaires, and pop and sports stars. The firm works alongside financial advisers, tax specialists, trustees, private bankers, fiduciaries and family offices, designing high-value IUL and PPLI strategies, multi-pay and premium-financed solutions, policy loan arrangements and trust-based planning.
Important information. Based on a real client case; names, personal details and figures have been changed or rounded. Information for professional advisers and their clients, not personal advice, a recommendation or an offer. Illustrative figures are examples on stated assumptions and are not guaranteed; policy charges apply. Clients should take independent tax and legal advice in each relevant country. Capital for Life Ltd, company no. 12976386. Registered office: 5 Brayford Square, London E1 0SG.
Capital for Life · For professional advisers and their clients · Information, not advice.
