High-net-worth (HNW) owner-managed businesses in the United States must carefully design buy-sell funding to preserve value, minimize tax leakage, and ensure continuity. Two common insurance strategies — single-life policies (one policy per owner) and survivorship (second-to-die) policies — each have distinct roles, costs, and tax consequences. This article provides a practical, U.S.-focused comparison (with examples for New York, California, and Texas owners) to help tax, legal, and financial advisors evaluate the best structure for buy-sell funding in HNW succession plans.
Executive summary
- Single-life policies are typically the default choice to fund buy-sell agreements because they provide liquidity at the first owner death, which is the usual buyout trigger.
- Survivorship policies are second-to-die and pay only after both insured owners die; they tend to be less expensive than two large single-life policies for the same combined face amount, but are usually not suitable to fund a buyout on a first death.
- For estate tax liquidity and transfer planning in high-estate-value states (e.g., New York), survivorship policies can make sense as a complement to single-life coverage, or as a replacement when buyouts are deferred to the second death.
- Premium financing and trust ownership (e.g., ILITs) are common structuring tools for HNW owners to optimize cash flow and estate inclusion.
How the two structures work — quick definitions
- Single-life policy: A life insurance policy on one individual. For two owners, the business or counterparty typically purchases one policy on each owner. Proceeds are available on the first insured death.
- Survivorship (second-to-die) policy: A single policy that insures two lives and pays a death benefit only on the later of the two deaths.
Primary objectives in buy-sell funding
- Provide immediate liquidity at the buyout event (usually a first death).
- Avoid business disruption and preserve value for remaining owners or purchaser(s).
- Optimize tax outcomes for the estate, business, and buyer(s).
- Preserve family wealth and minimize conflict in intra-family transfers.
Comparative analysis
When to use single-life policies
- Typical buy-sell trigger: Owner death; immediate need for cash to fund a purchase.
- Best for: Cross-purchase and entity-purchase buy-sell agreements that require funds at the first death.
- Advantages
- Delivers liquidity at first death
- Easier to align with cross-purchase or redemption structures
- Simpler valuation tie-in: proceeds used to buy established equity interest
- Disadvantages
- Two policies → higher aggregate premiums than a survivorship policy of the same combined face; but each pays on first death (the required outcome)
- Use cases by state
- New York or any state with an estate tax: single-life policies can be structured inside or outside trusts to optimize estate tax exposure and step-up basis outcomes.
- California/Texas: without state estate tax (as of 2024), single-life policy utility relates mainly to business liquidity and federal estate tax exposure.
When to use survivorship policies
- Typical buy-sell trigger: Not ideal for funding a buyout on first death — better as an estate liquidity tool to pay estate taxes or equalize inheritances at the second death.
- Best for: Estate equalization between heirs, funding deferred transfers, or replacing estate tax liabilities that arise at second death.
- Advantages
- Lower combined premium than two single-life policies for the same lump-sum benefit
- Useful for transferring wealth to heirs after both owners die
- Disadvantages
- No benefit at first death → not appropriate when a buy-sell requires funding at first death
- Can create liquidity gaps if business must be sold or capitalized immediately after the first death
- Use cases by state
- New York: survivorship policies can help pay estate taxes that may remain at the second death.
- California/Texas: useful primarily for federal estate tax planning only (state rules differ).
Cost comparison (illustrative 2024 sample ranges)
Note: Actual premiums depend on age, health class, product type (term vs permanent), underwriting, and insurer. Figures below are illustrative examples derived from publicly available rate guidance and typical market quotes (2024) for healthy, preferred nonsmoker lives.
| Scenario | Product type | Sample face amount | Illustrative annual premium (range) | Typical buyer |
|---|---|---|---|---|
| Single-life pair — Owner A & B, age 50 | 20-year term, $1M each | $2,000,000 total | $1,500 – $6,000 per owner (annual) → ~$3,000 – $12,000 combined | Small-business buyouts requiring near-term liquidity |
| Survivorship — couple, ages 50 & 50 | 20-pay survivorship universal life, $2M face | $2,000,000 total | $8,000 – $25,000 annually | Estate-equalization, tax liquidity at second death |
| Single-life — age 60 | Whole/universal life, $1M | $1,000,000 | $10,000 – $40,000 annually | HNW owners needing permanent insurance |
| Survivorship — ages 60 & 60 | Survivorship universal life, $2M | $2,000,000 | $15,000 – $45,000 annually | Estate planning where benefit at second death suffices |
Sources for pricing patterns: public rate guides and consumer quote platforms (see Sources). For precise pricing in New York, California or Texas, obtain insurer quotes because state approval, product availability, and underwriting vary.
Tax and ownership considerations
- Life insurance proceeds are generally excluded from gross income under IRC §101(a). However, proceeds may be included in the insured’s taxable estate under IRC §2042 if the insured retained incidents of ownership.
- To remove proceeds from the estate, HNW owners often use an Irrevocable Life Insurance Trust (ILIT). ILIT ownership typically prevents estate inclusion, assuming the insured has not retained incidents of ownership and the trust complies with timing rules (e.g., 3-year rule).
- Survivorship policies owned by an ILIT can fund estate taxes arising at second death; single-life policies in an ILIT provide first-death liquidity outside the insured’s estate.
- State estate taxes differ: New York (state estate tax) requires special planning due to a lower exemption threshold (NY Department of Taxation and Finance). California and Texas currently have no state estate tax but federal exposure remains.
Practical structuring recommendations for HNW buy-sells
- For owner-managed HNW businesses that require immediate funding at first death, purchase single-life policies on each owner, ideally owned by the buyer(s) or by a business entity consistent with the buy-sell structure.
- Where estate tax at second death is a major concern (e.g., New York residents with estates approaching the state/federal exemption), consider pairing single-life policies for buyout liquidity with a survivorship policy owned in an ILIT for estate-tax/equalization needs.
- For owners with limited current cash flow but substantial future liquidity, premium financing (borrow short-term to pay premiums) can be effective — coordinate with private banks (e.g., Bank of America Private Bank, Goldman Sachs Private Wealth, or specialty premium-finance brokers) and model risk (interest rate, collateral calls). See Premium Financing for Buy-Sell Policies: When Leverage Enhances Succession Outcomes.
- Carefully match policy ownership and beneficiary design to the buy-sell agreement type (cross-purchase vs entity-purchase). See our comparison: Cross-Purchase vs Entity-Purchase: Which Insurance-Funded Buy-Sell Works for Your Business?.
Example scenarios by state
- New York (high estate-tax risk): Owner couple age 62 with combined estate value > $10M — recommended: single-life policies owned by the business for immediate buyout liquidity + survivorship UL in an ILIT to cover NY estate tax risk at second death.
- California (no state estate tax): Owner age 55 selling to co-owner — recommended: single-life policies for buy-sell funding; survivorship may be unnecessary unless aimed solely at federal estate tax equalization.
- Texas (no state estate tax): Similar to California — focus on single-life permanent or long-term term depending on buy-sell horizon.
Implementation checklist for advisors
- Determine buy-sell trigger(s) and timing (first death, disability, retirement, divorce).
- Choose funding vehicle: cross-purchase vs entity-purchase; match to policy ownership.
- Obtain competitive quotes from reputable insurers (e.g., Northwestern Mutual, MassMutual, New York Life, Guardian) and compare term vs permanent vs survivorship pricing.
- Evaluate ILIT ownership to remove proceeds from estates and preserve step-up benefits for heirs.
- Model premium financing only with full stress testing of interest-rate risk and collateral requirements.
- Coordinate with valuation clauses and triggers in the buy-sell agreement (see Valuation Triggers and Insurance Coverage: Aligning Policy Design with Succession Events).
Conclusion
For HNW owner-managed businesses in the U.S., single-life policies are generally the correct choice to fund standard buy-sell agreements because they deliver liquidity at the first death. Survivorship policies are a valuable complement for estate-equalization and second-death estate-tax liquidity but are not substitutes when an immediate buyout is required. Use ILITs and premium financing selectively to align cash-flow, tax, and legacy objectives — and always integrate insurance design with your buy-sell agreement wording and valuation triggers.
Internal resources:
- Funding Buy-Sell Agreements with Life Insurance: Best Practices for Business Succession
- Cross-Purchase vs Entity-Purchase: Which Insurance-Funded Buy-Sell Works for Your Business?
- Premium Financing for Buy-Sell Policies: When Leverage Enhances Succession Outcomes
Sources
- "Second-to-Die (Survivorship) Life Insurance," Policygenius — https://www.policygenius.com/life-insurance/second-to-die-life-insurance/
- IRS — Estate and Gift Taxes overview — https://www.irs.gov/businesses/small-businesses-self-employed/estate-and-gift-taxes
- New York State Department of Taxation and Finance — Estate Tax — https://www.tax.ny.gov/pit/estate/estate_tax.htm
(Obtain insurer-specific, in-force quotes from carrier illustration departments — e.g., MassMutual, Northwestern Mutual, New York Life — when designing client strategies. Actual premiums and product availability vary by state and underwriting class.)