Springrocc is the leading firm in cross-border investment and insurance planning for U.S.-connected families and businesses.
Our proprietary Cross Border Insurance Illustrator™ (trade mark pending) validates projections and aligns designs with PFIC and U.S. IRC §7702 requirements.
Dual-jurisdiction planning requires precise investment selection and insurance design. Springrocc delivers a unified framework that addresses both Canadian and U.S. considerations.
PFIC rules in U.S. tax law limit deferral on certain non‑U.S. investment holdings. When a U.S. person owns shares in an entity that primarily earns passive income (or holds passive assets), the IRS may classify it as a PFIC—often impacting taxation and reporting.
Investment menus are screened for PFIC exposure. Portfolio components are selected or substituted to avoid inadvertent classification and to align with U.S.-reporting practicalities.
We coordinate with U.S. tax counsel and international custodians. PFIC‑sensitive assets are documented, look‑through tested when applicable, or replaced with compliant vehicles.
Section 7702 defines what qualifies as a life insurance contract for U.S. tax purposes. It governs testing methods—the Guideline Premium Test (GPT) and the Cash Value Accumulation Test (CVAT)—to ensure a policy functions as life insurance rather than as an investment account.
All U.S.-connected designs are modeled in our Cross Border Insurance Illustrator™ using GPT and CVAT frameworks to confirm §7702 qualification at issue and over time.
Illustrations include parallel 7702 calculations, documenting death benefit corridors, guideline limits, and cash value thresholds in plain language for client files.
From PFIC‑aware investment construction to §7702‑tested insurance structures, Springrocc integrates both regimes into one coordinated plan. Our proprietary engine (trade mark pending) supports decisions with auditable math and clear reporting.
Discuss PFIC‑safe allocations and §7702‑tested insurance design.