Very often when a large estate tax problem is looming the attorney and other advisors will recommend using life insurance to address the estate tax liquidity issue. This is because insurance provides immediate liquidity when one passes and also because it is by far the most efficient way to pay the estate taxes (paying each dollar of tax for 15-20 cents).
And when sizable amounts of insurance coverage are needed this can present an issue as those premium dollars must be gifted to the Trust holding the insurance & that can create potential gift tax issues.
By loaning those dollars to the Trust vs gifting, this can eliminate the gift tax issue. Furthermore, because it is a loan those dollars can be paid back to the client/grantor. So think of it as moving money from your left pocket to your right pocket. And if these funds are properly invested, the earnings can be used to pay the premiums vs using the principal to pay the premiums.
End of the day, the client can acquire a sizable amount of insurance to pay the estate taxes with heavily discounted dollars, while avoiding gift taxes all while also being repaid. It’s an extremely effective strategy and solves many issues at once.