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This strategy leverages tax arbitrage between the United States and Puerto Rico using Act 60. It recognizes losses today and indefinitely postpones the offsetting gain. Using IRC 704(b) and a 475 election, the structure is highly flexible and can be tailored to a wide range of income types. On a $1MM income loss scenario: put up $200K, receive $75K back (7.5% of the K-1). The 4% debt service on the line of credit is covered by the returned funds. GFX pays 4% tax but earns 5% of the income — netting a favorable arbitrage for all parties.

Designed for high-net-worth business owners and investors with $5M–$30M in assets, the strategy eliminates capital gains tax before attorney fees and creates a structure for tax-free growth, tax-free income withdrawals, and completely tax-free wealth transfer to heirs. This strategy requires planning at least 45 days prior to an asset sale and has a 2-year minimum commitment. It is ideal for clients approaching a major liquidity event such as a business sale, property disposition, or large investment exit.

This strategy converts a traditional 401(k) or IRA into a Roth IRA with minimal tax consequences using the Infinite Banking Concept via life insurance policies (Pacific Life). Expenses are accelerated in year one to reduce the tax basis — on a $3MM balance, the basis is reduced to $2MM. That $2MM tax bill is then offset with a charitable contribution leveraged 20-to-1, maxing at 60% of AGI via a 501(c)(4) foundation. Loans can be taken on policy assets without triggering a taxable event. Tax benefits can be activated within 45 days. Funded over 2–5 years. Surrender charges are high — this is a permanent strategy.

Equiplease leverages Section 179 of the IRS code to purchase boom lifts and capture 100% bonus depreciation in the same tax year. The client puts down only 20% — the remaining 80% is funded through a newly formed LLC. The LLC is managed by an equipment leasing company, making this a largely passive strategy. Depreciation flows through to offset active income, resulting in up to 65% tax savings in the year of purchase. No long-term liquidity commitment is required.

Governed by Section 453, this strategy establishes an Intermediary Trust that becomes the legal owner of the asset. The trust sells the asset to the buyer and retains the entire pre-tax sale proceeds. The client receives an installment note in return, and the Trust uses the proceeds to purchase an Indexed Universal Life (IUL) policy. Capital gains are indefinitely deferred, the IUL grows tax-advantaged, and the client retains access to liquidity through the installment structure. Must be initiated at least 60 days prior to the sale with a 2-year minimum holding period.