俄乌战争令芯片供应雪上加霜？台积电、英特尔、三星这么说
凤凰科技
02/24/2022
北京时间2月24日消息，目前为止，大型芯片公司都预计，俄罗斯与乌克兰的战争危机对供应链的影响有限，这得益于他们的原材料储备和多样化采购，但是一些业内人士担心其长期影响。
这场危机已经打击了那些在全球采购或销售产品的科技公司股票，原因是人们担心，俄乌战争将会令持续一年的半导体芯片供应短缺局面雪上加霜。
直接影响有限
乌克兰为美国供应了90%以上的半导体级氖气，该惰性气体对于芯片制造所使用的激光至关重要。市场研究公司Techcet称，氖气是俄罗斯钢铁制造业的副产品，在乌克兰进行提纯。美国目前有35%的钯元素来自俄罗斯，该元素主要用于传感器和存储器制造。
“芯片制造商并未感受到任何直接影响，但为他们提供半导体制造材料的公司会从俄罗斯和乌克兰购买氖气和钯等气体。这些材料的供应本来就很紧张，所以任何进一步的供应压力都可能推高它们的价格，进而可能导致芯片价格上涨。”日本芯片行业知情人士称。
但是，由于其他中断和冲突事件，芯片公司对于原材料的准备比近几年要好，这让他们减轻了一些芯片供应短缺的痛苦。知情人士称，白宫已提醒芯片行业要实现供应链的多样化，以防俄罗斯对美国威胁的出口限制采取报复措施，阻止关键材料的获取。
英特尔、台积电、三星都怎么说？
作为台积电、三星电子、英特尔等芯片制造商的关键荷兰供应商，阿斯麦周三表示，公司正在研究氖气的替代来源。
韩国存储芯片制造商SK海力士CEO李锡熙(Lee Seok-hee)上周告诉记者，该公司已经“获得了大量”芯片材料，“没有必要担心”。
三星表示，俄乌局势对芯片生产没有直接影响，正在密切关注事态发展。三星称，受益于多元化材料来源，生产照常进行。
英特尔称，公司预计不会受到任何影响。晶圆代工商格芯(GlobalFoundries)表示，乌克兰战争预计不会产生直接风险，公司可以灵活地在俄罗斯或乌克兰以外寻找资源。台湾芯片制造商联华电子也这么认为。
全球最大芯片代工商台积电拒绝在“此时”置评。台湾芯片测试和封装公司日月光半导体表示，“此时”的材料供应保持稳定。中国台湾“经济部”在一份声明中称，他们已检查了台湾的半导体供应链，没有发现材料或生产活动受到直接影响。
“俄罗斯目前不是台湾芯片代工行业的主要市场之一。” 市场研究公司集邦科技高级分析师乔安妮·焦(Joanne Chiao)表示。
马来西亚芯片封装公司Unisem表示，从原材料的角度来看，该公司预计芯片生产不会受到影响，因为其所需的材料并非来自俄罗斯，其设备主要来自美国、日本、韩国、新加坡和当地。Unisem的客户包括苹果公司。
现在，马来西亚已成为芯片生产链中的重要一环，占全球芯片组装测试和封装的13%。
【视频】全球十大富豪疫情期间财富翻倍
联合早报
02/13/2022
冠病疫情让贫富差距加大，但具体情况有多严重？乐施会最近的一份报告，用数字量化了全球穷人和富人之间的财富鸿沟。
全球十大富豪疫情期间每天进账几亿？他们的财富加在一起要多久才能花完？富豪榜单上有哪些新面孔？什么行业是最新造富摇篮？点击视频了解详情。
全球102名百万富豪联名呼吁各国政府即刻征收财富税
来自 / 联合早报 | 整理 / 李月霞
01/19/2022
（苏黎世综合电）据估算，如果向全球顶尖富豪征收“富人税”，每年至少可获得2.52万亿美元（3.40万亿新元），足以资助每个人接种冠病疫苗，并帮助23亿人脱贫。
消除不平等联盟、慈善机构“乐施会”、总部设在美国的“政策研究所”和“爱国百万富豪”等组织近日联手展开一次调研，他们昨天发布报告，主张以累进税率向富人征税。他们的研究显示，对500万美元以上的财富征税2%，5000万美元以上财富征税3%，10亿美元以上财富征税5%，可以筹集2.52万亿美元，这笔钱除了可让23亿人摆脱贫困之外，还可为中低收入国家的36亿人提供全民医疗和社会保险。
该调研报告指出，如果向亿万富豪的10亿以上财富征收10%的税，那每年可获得的富人税就可达3.62万亿美元。
“爱国百万富豪”组织的102名成员包括迪士尼继承人阿比盖尔（Abigail Disney）昨天发出公开信，向出席世界经济论坛的政界领袖发出呼吁，要政府现在就向他们征收财富税。他们指出，现行的征税制度不公平，是为“让富者更富”而设计的。“世界应该要求富者支付他们应当承担的税额……对我们这些富者征税，现在就对我们征税。”
联署的富豪来自美国、加拿大、德国、英国、丹麦、挪威、奥地利、荷兰和伊朗等国。
日前一份独立报告显示，在冠病疫情蔓延的这两年里，全世界最富有的那群人变得更加有钱。乐施会本周发布的一项研究显示，世界前10名首富的财富已经翻倍至1.5万亿美元，即每秒增加1万5000美元。
消除不平等联盟全球召集人珍妮·瑞克斯在声明中说：“在冠病疫情期间，数十亿人每天为生存苦苦挣扎，亿万富豪的财富却失控般飙升，这是不对的。”
据了解，除了少数一些国家，多数地方的富人不必每年为房地产、股票或艺术品等资产缴税，只在资产出售时才纳税。
世界经济论坛：可参考瑞士财富税模式
世界银行去年发表一篇文章，敦促各国考虑征收财富税，以帮助减少不平等，补充因国民支援计划而耗尽的国库，并重新获得社会信任。
世界经济论坛发言人说，征收公平的税款是论坛的宗旨之一。论坛总部所在地瑞士所征收的财富税，可能是其他地方可采纳的一个很好的模式。
White House: 400 wealthiest families paid average tax rate of 8.2 percent
BY NAOMI JAGODA
9/23/2021
The White House released an analysis on Thursday estimating that the 400 wealthiest American families paid an average federal income tax rate of only 8.2 percent on $1.8 trillion of income from 2010 to 2018.
“Two factors that contribute to this low estimated tax rate include low tax rates on the capital gains and dividends that are taxed, and wealthy families’ ability to permanently avoid paying tax on investment gains that are excluded from taxable income,” the report said.
The analysis, which was authored by economists from the White House Council of Economic Advisers and the Office of Management and Budget, comes as Democrats in Congress are working on a tax-and-spending package that would advance much of President Biden‘s agenda. Biden has proposed a number of tax increases on the wealthy and corporations in order to pay for his spending priorities in areas such as health care and child care, and he is seeking to prevent moderate congressional Democrats from scaling back these proposals.
The White House analysis is based on IRS statistics, the Federal Reserve’s Survey of Consumer Finances, and Forbes magazine estimates about the 400 wealthiest Americans.
The White House noted that its estimate of the tax rate for the wealthiest households is “much lower” than other groups’ estimates of top income tax rates. The administration’s takes into account income from unrealized capital gains, which is not typically included in this type of analysis.
The report highlighted Biden’s proposals to raise the top capital gains rate and end the “stepped-up basis” tax preference that benefits heirs as ways to address the fact that wealthy Americans pay a low tax rate.
Legislation approved by the House Ways and Means Committee earlier this month included a smaller capital gains increase than Biden had proposed and does not repeal stepped-up basis. But Senate Democrats are expected to offer their own ideas for how to pay for the spending package, and Finance Committee Chairman Ron Wyden (D-Ore.) has indicated that he wants to prevent billionaires and their heirs from avoiding taxes on stock gains.
Wyden said in a statement Thursday that “the White House’s new report is shocking but not surprising.”
Top 1 Percent Avoid Paying $163 Billion in Taxes Each Year: Treasury Department
By Leia Idliby
9/08/2021
The Department of Treasury has found that the wealthiest one percent of Americans have avoided paying $163 billion in taxes per year.
The Treasury’s analysis, titled “The Case for a Robust Attack on the Tax Gap” and written by Deputy Assistant Secretary for Economic Policy Natasha Sarin, opens by explaining, “A well-functioning tax system requires that everyone pays the taxes they owe.”
The report argues that narrowing the tax gap, which accounts for the difference between owed and collected taxes, will lead to a more equitable economy, as it currently “totals around $600 billion annually,” which would lead to “approximately $7 trillion of lost tax revenue over the next decade.”
Sarin’s report includes a table detailing tax data from 2019, which ultimately found that more than $160 billion lost annually is “from taxes that top 1 percent choose not to pay.”
The report goes on to argue that in order to collect owed taxes and enforce laws against high earners and corporations, the IRS needs funding to update their technology and to hire agents able to decipher “thousands of pages of sophisticated tax filings.”
“It also needs access to information about opaque income streams — like proprietorship and partnership income — that accrue disproportionately to high-earners,” she wrote.
The reports comes as President Joe Biden’s administration is pushing for a significant increase to the IRS budget. The White House has specifically called for $80 billion of investment over the next ten years, claiming it would help the government catch tax evasion schemes.
“Giving the IRS the information and resources that it needs will generate substantial revenue,” Sarin concluded. “But even more importantly, these reforms will create a more equitable, efficient tax system.”
Top 0.1% Tap Private Placement Life Insurance to Avoid Biden’s Taxes
Financial Advisor IQ
9/04/2021
The richest Americans who want to avoid paying higher taxes under President Joe Biden are tapping a niche product that has become more generally available, cheaper and flexible in recent months.
Some advisors who cater to the top 0.1% say that private placement life insurance is “dominating conversations,” according to Bloomberg.
Assets held in PPLI policies are tax-free, and when a policyholder dies, their heirs inherit the policy’s contents tax-free, Bloomberg writes. Assets inside a PPLI can also be brorrowed against or rolled into another insurance product, according to the news service.
PPLI policies, however, have complicated rules to qualify as life insurance to take advantage of the tax benefit, can fail if not properly funded and taking assets out comes with a heavy tax burden, Bloomberg writes.
“Clients are very interested in this right now,” said Tara Thompson Popernik, director of research for Bernstein Private Wealth Management’s wealth planning and analysis group, according to Bloomberg. “It takes some education to get them to wrap their heads around the concept, because it’s not just buying life insurance.”
But it’s not just the threat of Biden going after billionaires and millionaires to pay their “fair share” that’s making the loophole: a late-2020 insurance law change made PPLI “more powerful,” while competition among insurers has pushed down costs while increasing the choice of products, according to Bloomberg.
“Private placement life insurance poses a serious obstacle to President Biden’s goal of guaranteeing that high-income individuals pay tax on large gains at least once per lifetime,” said Daniel Hemel, a law professor at University of Chicago, according to the news service. “PPLI is a massive loophole — entirely legal, easy to exploit, and politically very hard to close.”
How Does Private Placement Life Insurance Work?
By Maxime Croll
9/04/2021
Private placement life insurance (PPLI) is a niche solution designed for wealthy individuals in high tax brackets who have a few million dollars available to commit.
Many times, those for whom PPLI was designed want to invest in hedge funds, but hedge funds can carry significant taxes: If the wealthy individual invests in them in their personal name, in a taxable account or in a trust, every trade the manager makes can generate a capital gains distribution, and any ordinary income is taxable at particularly high rates.
That’s a serious issue at higher income levels, where combined federal and state income and capital gains taxes can easily add up to nearly 50% in some jurisdictions.
One increasingly popular solution: Hold these assets within a life insurance policy.
Who does private placement life insurance make sense for?
PPLI isn’t for everybody. A good candidate for this strategy is someone with annual income in the millions, a net worth of $20 million or more or someone who controls a business that puts them in that category.
Life insurance comes with a number of important tax benefits, which can be major considerations for those in the highest tax brackets. But standard life insurance policies you can get from your neighborhood agent don’t contain the hedge funds, funds of funds and other alternative investments that these investors require for their own diversification and investment needs.
That’s where privately placed life insurance comes in: Wealthy families, family foundations, trusts, corporations and banks work with hedge funds and money management firms to create their own life insurance contracts, designed to reduce their tax burdens.
The idea is to combine the financial advantages of highly taxed hedge funds and similar investments with the tax advantages of life insurance. There are insurance and administrative costs associated with the life insurance contract, but the tax savings in a properly structured life insurance policy, plus the death benefit itself, more than make up for the additional insurance and administrative costs. And the insured can generally access most of the funds anyway, tax-free, via policy withdrawals and loans.
When a wealthy investor in a very high tax bracket wants to invest in hedge funds anyway, it often makes sense to create a privately placed life insurance policy to shelter the individual from taxes.
Qualifications to purchase PPLI
While anyone can buy a variable universal life insurance policy (as PPLIs are structured), PPLIs are an unregistered securities product. As such, agents can only present them to accredited investors.
Under current Securities and Exchange Commission (SEC) regulations, accredited investors are those with a net worth of at least $1 million (excluding primary residence), or income of at least $200,000 in each of the preceding two years. Married couples must demonstrate income of $300,000 in each of the preceding two years.
Ultimately, the owner is typically an individual or a trust. Holding the policy in an irrevocable trust allows the insured to keep the policy out of their taxable estate, possibly reducing eventual estate tax liability, though they give up rights to access the cash value prior to death.
In reality, the typical PPLI candidate or family has:
- A high net worth
- The ability to fund $1 million or more in annual premiums for several years, at least — $3 million to $5 million is typical
- A desire for hedge fund or alternative investment exposure
- Highly tax-inefficient investments
- High state and local income taxes in addition to federal (advisors should be alert to the effect of any state premium taxes on the strategy)
- A desire to shelter assets from creditors
It’s important to be able to make a significant investment over the first several years as this initial investment of premium “primes the pump,” meaning that, assuming the underlying investment subaccounts perform adequately, the insured’s policy can become self-funding. That is, growth in its cash value covers the cost of insurance. At that point, the insured can cease committing premium if they choose.
Where to buy private placement life insurance
Professional wealth managers tend to recommend vendors. However, some of the most prominent providers of PPLI services and insurance-dedicated funds (IDFs) include BlackRock, Wells Fargo Private Banking, John Hancock, Zurich, Crown Global and Pacific Life.
How private placement life insurance works
Privately placed life insurance is generally structured as a variable universal life insurance policy, meaning:
- Premiums are flexible. Policyholders can pay as much or as little premium as they like, whenever they like.
- The cost of insurance is deducted from the cash value in the policy subaccounts each month or each year.
- To keep the policy in force, the owner must pay enough premium to maintain enough cash value to cover the cost of insurance.
- If the cash value reaches zero, the policy will lapse.
The agent who sets it up will usually structure the policy to maximize cash value accumulation while keeping the death benefit (and thus the cost of insurance) relatively low. The policy owner, working with their insurance professional, then pays as much premium into the policy as possible every year.
The client gets the benefit of the tremendous tax advantages of the life insurance contract:
- Tax-free death benefits to heirs
- Tax-deferred growth of cash value
- Tax-free growth of dividends (if applicable)
Meanwhile, the insured still has access to accumulated cash values, which can be used for any purpose and accessed at any age. There are no penalties for accessing the cash value before turning age 59 1/2, as there are with annuities and with individual retirement accounts (IRAs). In addition, there are no required minimum distributions, as there are with annuities, IRAs and retirement accounts.
PPLI investments
As discussed, the best investment candidates for a PPLI policy are those that are tax-inefficient. They generate substantial current taxable income, imputed (phantom) income or capital gains unless they are held in a retirement account or life insurance vehicle that provides tax-free growth.
PPLI owners and their advisors either choose specific investments for their portfolios or carefully select money managers to manage their portfolios within the policies. Possible investments can include venture capital, real estate investment trusts, private equity funds, funds of hedge funds and commodity funds, or any fund with extremely high turnover rates that generate substantial short-term capital gains.
But that doesn’t mean anything goes. PPLIs must still meet IRS standards for investor control, insurance and diversification.
Investor control. Individual policy owners and family offices are prohibited from exercising influence over the specific investment decisions of the fund managers. If the owner exercises too much control, the IRS may disqualify the tax advantages of the policy. Current case law requires managers to operate on an independent, discretionary basis. Assets held in PPLI policies are not designed to be separately managed accounts, and they should not be treated that way.
Insurance standards. The life insurance structure allows owners to sell insurance-dedicated funds within the policy as often as they like and replace them with other qualified investments, without tax consequences. IDFs are financial products that are designed specifically for the PPLI market. Hedge funds and funds of funds often create a version of their flagship offering as an IDF that uses all the same strategies and managers but is also managed to adhere to laws and regulations that govern insurance portfolios.
Diversification requirements. Investments must also meet diversification rules:
- No single investment may make up more than 55% of the insurance subaccount portfolio.
- No two investments may constitute more than 70% of the portfolio.
- No three investments may constitute more than 80% of the portfolio.
- No four investments may constitute more than 90% of the total assets of the account.
Therefore, the portfolio must, in practice, contain a minimum of five distinct investments in order to fully qualify as life insurance. Otherwise, the IRS will disqualify the policy, and the owner will lose the tax advantages of the life insurance structure.
Accessing your money in a PPLI
Policy owners can withdraw from their cash value or borrow against it at any time, for any purpose.
Withdrawals Withdrawals are tax-free up to the basis of the policies. So owners can get back their premiums, minus fees, without tax consequences — as long as their subaccounts’ performance has kept up with the cost of insurance. If the cash value is greater than the owner’s basis in the policy — that is, what they have paid in — then additional withdrawals in excess of basis are taxed as a gain.
Policy loans You can borrow against the cash value of the policy with no underwriting or credit check. The loan is secured by the policy’s cash value. This makes the policy a solid choice for emergency funds. The loan does not have to be paid back, though the policy owner may want to replenish funds borrowed from the policy so as to maximize long-term tax-free growth.
Because the loans are secured by payments already made to the insurer, interest rates are often very low. Borrowers should be aware that interest does accrue, and borrowing will reduce any death benefits paid out unless the loan is paid back to the policy.
Contribution limitations and modified endowment contracts
The government imposes limits to how much premium the owner can contribute to the policy in a given year in order to help ensure life insurance is used for its intended purpose, as opposed to a tax shelter. The result of the contribution limit is the “seven-pay” test. If policyholders contribute so much premium to their policies that the policy would be paid up in less than seven years, it becomes a modified endowment contract (MEC). This will disqualify the policy from many of the tax advantages on withdrawals and loans:
- One of the great things about insurance policies is that when you withdraw cash value from an in-force life insurance policy, you get the benefit of first-in, first-out (FIFO) taxation. This allows you to withdraw as much as you’d like, up to your basis in the policy (the amount you have contributed), tax-free. If your policy becomes an MEC, this advantage disappears. Instead, the IRS will deem you to be withdrawing interest first, not your basis. This interest is taxable.
- Likewise, while the law allows you to take tax-free loans from a life insurance policy, once your policy becomes an MEC, those loans become taxable as income.
- Additionally, once your policy becomes an MEC, any withdrawals prior to age 59 1/2 become subject to a 10% early withdrawal penalty, just as with a qualified annuity or a 401(k).
Your policy documents should specify the annual MEC limit.
| Life insurance contract | MEC | |
|---|---|---|
| Premiums | Limited by seven-pay test | Not limited except by contract |
| Loans | Tax-free for life of policy | Taxable as income |
| Withdrawals | Tax-free up to basis (FIFO) | Taxable until all interest/gains are withdrawn |
| Death benefit | Tax-free | Tax-free |
| Death benefit amount | Usually kept small in PPLI to maximize growth of cash value | Used to maximize death benefit |
How are PPLI policies different from retail life insurance?
Structurally, privately placed life insurance is identical to a conventional variable universal life insurance policy. What sets the PPLI apart is the assets held in the subaccount: An everyday retail customer will choose from a limited menu of subaccount investments offered by the life insurance company.
But when you buy a PPLI, you can customize your investment subaccounts. You can include nearly any investment imaginable — from index funds to hedge funds. Your registered investment advisor or wealth manager can help design the investments in your menu of subaccounts.
Tax and other benefits of PPLI
High-income individuals are very tax-sensitive. The ordinary income tax rate on incomes above $518,401 in 2018 was 37%, plus additional Affordable Care Act taxes on high-income individuals. When you add in state and local income taxes in some jurisdictions, the income tax bite for high-income families could add up to nearly 50%.
The heart of the PPLI strategy lies in the tax advantage. The PPLI essentially converts a very tax-inefficient investment, such as a hedge fund, into a very tax-efficient one for the high-net-worth investor.
| Hedge fund held in personal account (typically) | Hedge fund held within a PPLI | |
|---|---|---|
| Death benefit | N/A | Tax-free death benefit |
| Income | Taxable at 37%-50% | Tax-free for life of policy |
| Short-term capital gains | Taxable at 37%-50% | Tax-free for life of policy |
| Long-term capital gains | Taxable at 20% | Tax-free for life of policy |
| Imputed income | Taxable at 37%-50% | Tax-free for life of policy |
| Transfers to other life policies | Taxable, gain over basis | Tax-free under IRC Section 1035 |
| Transfer to annuities | Taxable, gain over basis | Tax-free under IRC Section 1035 |
| Creditor protection | None | Enhanced |
| Estate tax treatment | Taxable unless in irrevocable trust | Taxable in estate of owner unless in irrevocable life insurance trust |
| Tax loss harvesting strategies | Investors can sell losers to offset capital gains | N/A, though losing policies can be surrendered |
| Treatment at death | Subject to probate | Bypasses probate — death benefit goes to beneficiaries in a matter of days |
This strategy neutralizes the impact of current income by placing the assets within a life insurance policy, with tax advantages similar to a Roth IRA. Assets within the policy enjoy tax-free growth for as long as they remain in the policy.
In addition to the tax benefits that generally accrue to life insurance cash values, PPLI policies often provide a number of additional benefits:
- Lower commissions. The cost of insurance and commissions is low compared to most retail life insurance products: Issuers are more interested in managing your money than in generating large upfront commissions.
- No surrender charges. Because they don’t rely on a commission-paid insurance sales force as traditional insurance companies do, they don’t need to recoup commission costs by imposing surrender charges.
- Phantom income is not taxed. Some investments generate a tax liability to the owner, even though there is no actual cash income distributed. For example, a zero-coupon bond pays no income until it matures, but the IRS forces taxpayers to pay taxes on imputed income as the bond approaches maturity. If the asset is held in a PPLI, the tax on imputed or phantom income is neutralized.
- Tax compliance is easier. Tax reporting is a constant headache for hedge fund investors and those who hold interests in limited partnerships and master limited partnerships. By holding these assets within a PPLI, the taxpayer can eliminate having to deal with K-1 reports and other reporting requirements.
- Creditor protection. Cash value life insurance is a proven way to shelter assets from creditors. Life insurance and annuities enjoy substantial asset protection in every state, and in some states, like Florida and Texas, creditor protection is unlimited. In some cases, PPLI life insurance assets are held offshore — placing these assets out of the reach of U.S. courts. No U.S. court can force a foreign company to release funds to a creditor.
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