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A investor obtains for a small premium, for example $1,000, a life insurance policy from a tax haven based life insurance company. The policy can be surrendered at any time. 2. At the same time, the investor subscribes for units in an Australian resident unit trust to the value of, for example, $100,000. Payment for the units may be funded by a loan from a tax haven based bank related to the life insurance company at an interest rate of, for example, 10%. 3. The unit trust invests the funds from the unit subscription into an Australian resident company. 4. That company enters into an Investment Agreement with the life insurance company to invest the $100,000 into the same life insurance policy purchased by the investor for a guaranteed return which approximates the interest rate on the investor's loan, 10%. Under the terms of the Investment Agreement the company will receive a return of, for example, 3%. The balance of the income, being 7%, will accrue on the life insurance policy for the benefit of the investor. 5. The company pays this return of 3% as franked dividends to the unit trust. In turn any profit the trust makes after deducting various fees and expenses will be distributed to the investor. 6. The investor receiving a distribution of income claims a rebate for the franking credits and deductions for the interest payments made on the borrowing. 7. After 10 years the company surrenders its interest in the life insurance policy and receives its invested amount of $100,000. The company is liquidated with a capital return to the unit trust of $100,000 whose units in turn will be redeemed allowing the investor to use these funds to pay out the borrowing. 8. At the time of this surrender by the company, the amounts that have accrued on the life insurance policy will be paid to the investor.
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