09/15/2026
Brazil Today
Lei 14.754 closed automatic deferral inside many passive offshore companies. It did not repeal life insurance.
For a Brazilian tax resident holding wealth through a controlled foreign company, adjusted profits are now generally pulled into Brazilian tax every December 31 at 15% — distribution or not. That leak is structural, not optional.
Redeemable foreign life policies sit on a different timetable. Income is generally taxed when effectively received, not marked to market each year. And at death, indemnities paid to named beneficiaries are generally IR-exempt, with the capital treated as outside the estate — which is the statutory basis for bypassing inventário and, in the usual case, ITCMD that can reach 8% depending on the state.
The new case study walks through one family: age 67, roughly US$40 million offshore, two adult children, no need for large withdrawals. Keep compounding during life, transfer cleanly at death.
The important part is what has to be true for it to work:
→ Genuine risk transfer — a thin death benefit over a wrapper fails
→ Scale — charges of 0.5–1%+ a year mean this rarely makes sense below US$10–15M
→ SUSEP and ownership design, handled with insurance counsel rather than improvised
→ DIRPF reporting, plus Central Bank filings above the thresholds
→ Investor control and diversification rules that keep the contract insurance
The real question isn't whether PPLI is fashionable. It's whether the policy still reads as life insurance when Receita Federal, the heirs, and the insurer all look at the same contract.
Full case study: https://blog.ewp-financial.com/how-brazilians-use-ppli-to-avoid-15-tax-inventario/
Educational discussion only — not tax, legal, or insurance advice.
Brazil. PPLI After Lei 14.754. How One Brazilian Family Can Keep Compounding and Pass Capital Without Inventário. ~ by Michael Malloy.
