EFTA01454211

without the adverse U.S. tax consequences typical of offshore investments. Moreover, the client's portfolio should be sheltered from U.S. taxation during his stay in the United States. Retirement Planning Many clients, especially business owners, are subject to qualified plan limitations and can't put as much as they would like into tax-deferred retirement vehicles. These clients could use a PPVA investment account as a simple, yet effective, tax-deferred savings vehicle. The tax-deferred accumulation allows the PPVA account s•-)oi :d elapiE? :ay-evEr-•r:):: rive;y: n to generate substantial incremental retirement income relative to a taxable investment account. "Optimizing Retirement Income," this page, shows how much more can be withdrawn each year from a retirement account allowed to accumulate for different periods. When allowed to accumulate for 20 years, a PPVA investment account allows a client to withdraw almost 50 percent more per year for 20 years than a tax- able account. Practice tip: Consider allocating the most tax-ineffi- cient segment of a client's portfolio to the PPVA invest- ment account. This will optimize the leverage derived from deferring the investment gains from current period taxation. The PPVA provides significant flexibility in managing a client's retirement income, because sched- uled withdrawals can be postponed or accelerated as needed. If the PPVA investment account values arc allocated to alternative asset class investment vehicles, careful planning is necessary to assure that the required Optimizing Retirement Income If your client contributes $5 million to a PPVA account or taxable account and allows that money to accumulate for la 20 or 30 years. and then the client takes equal distributions for the next 20 years, here's what the annual distributions will be for each scenario 2500.000 2.0041.000 1500.000 1,000,000 503.0430 Taxabk mestmert &cart (alter tax) • PVJA mrestmenl anon! (after tax) 5503.120 $50.01MMIXIOSINVIIPSMIXIRS 9.95410 t1.0:6.912 910,12COspemismomm 9a223 44444,44-444444444—saumonow 0 0 10 20 9J 40 50 Yeas Assumes 1.5 cocert of kncl mageort lees adal peent reanettu kat mom( lees ona S5 (Ikon ermstnert n a laxibk a«c(ni ard a vitae *Tent ouble Emuities mount 75 went °treated gait ae Wel at ordm n(ere rates: aid no +sithlethals ae male Niue a;e 591 Maw korne Um* is assumed to be 4)3 Ducal litir I allTsi Ascent ttereher (mild gans tax rate is 20.7 percent in Yea I &IN I percent thereakt. Assures Ow Areinxsanert rnyugament lees aten'ttax &Wile in tne taxatie iwslinert u(contdue to Ile 2 peKertot aflusialuoss t itietdd ft( milted (Worts Distrtutior6 ae shown on artend-ohea basis - SAL.! Fund 5C-TVICE'S liquidity notices are submitted to the investment manag- ers in a timely fashion. Foundations with UBT Investments Many charities and charitable trusts allocate to asset classes that are deemed to be active business interests, rather than passive investments. These asset classes gen- erally generate UBTI; for example. timber, certain types of real estate, energy transportation and master limited partnerships, which can create current tax liabilities and even endanger the charitable entities tax-exempt status. A PPVA investment account could be a simple, effective 24 TRUSTS 4 ESTATES / wealthmanagement.com CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DECEMBER 2012 DB-SDNY-0112192 SDNY_GM_00258376 EFTA01454211