Tier One: Grayson Dufrene

This month, Jay sits down with Grayson Dufresne, Managing Director of Vie International in London. Grayson shares his two-decade perspective working with globally mobile clients, explains what actually changes when life insurance planning crosses borders, and discusses why policy design has to account not just for the insured, but for beneficiaries who may live in different tax systems over time. They also explore how recent UK tax changes are reshaping planning conversations and why families considering a move into or out of the U.S. need to start planning earlier than they think. Read on to learn more!

JAY:  As I was preparing for this interview, Grayson, it dawned on me that 2026 marks 20 years since we first met when I visited London as the Chief Distribution Officer for Sun Life’s Bermuda Branch.  Over this time, you have worked tirelessly to stake out a unique position in the global, high-net-worth life insurance marketplace.  I would go so far as to say you are the foremost expert on applying life insurance solutions in the overlapping space of U.S. and U.K. client matters.  Let’s get started by hearing about your London-based firm, Vie International, and your role in the organization.

GRAYSON: Thank you, Jay.  It’s amazing how time flies.  Our firm, Vie International, is a unique business that focuses on working with affluent individuals and families on cross-border US and UK life insurance and financial planning matters.  We are fully licensed to conduct business in both the US and UK and understand the needs of US clients that live in the UK and in other parts of the world.

There are many roles that I take on as the Managing Director which include management of staff, UK compliance, revenue generation and profitability.  In addition, I’m committed to mentoring new producers and growing the business to provide for the future of our clients and staff.  My primary aim is to make sure that our clients have the best experience possible in providing for their families.

JAY:  You have spent over half of your life in the U.K. so I am certain it may come as a surprise to some that you hail from New Orleans.   Can you connect the two places by talking about your upbringing and your path to where you are today in the top tier of the life insurance community?

GRAYSON:  I come from a very middle- class family from a small community just south of New Orleans.  I was the middle child in a family of three boys with family and sports playing a very big part of my childhood.

As a student athlete in high school, I learned about teamwork and competition from a very early age.  After graduating from high school, I worked my way through university and graduated from Loyola University New Orleans. 

Being a new graduate, I found myself looking for opportunities in business but being unsure of what would be the right career path.  A few months later, I received a call from a family friend who wanted to recruit me into the life insurance business.  Not knowing anything about the business, I took a leap and entered the profession eager to learn and become successful.  My career started in 1994 as an agent for a Fraternal Insurance Company based out of New Orleans

The real turning point in my life happened in 1994 when I met my future wife who was from the UK.  Karen really opened my eyes about UK culture which started me thinking about moving abroad and a new career move.  After responding to a recruitment ad in a life insurance selling magazine to work in Europe, I found myself, at age twenty- six, purchasing a one-way ticket to the UK and a job working in the international life insurance space.

Although the UK has been our home for the last thirty years, New Orleans still holds a special place in my heart and Karen and I keep a second home there which comes in handy for both family and business purposes.

JAY:  I recall you telling me that your life mirrors that of many of your clients.  Your family members are both U.S. and U.K. citizens, you reside in the U.K. and you are a business owner.   If someone like you is a U.S. taxpayer living in the U.K. and needs life insurance for estate planning purposes, is it as simple as purchasing a policy from a U.S. carrier?

GRAYSON:  As a US citizen who has lived in the UK for many years, with a British wife and adult US/UK children, my personal circumstances are quite like our client base at Vie International.  Many of our clients are US and UK blended families who have tax liabilities in both countries.

As life insurance tax rules are different in the US and UK, it’s important to understand how to design life insurance policies so that they are suitable for both US and UK planning.  Things such as the funding of policies via ILITs and cash value accumulation are treated very differently in the US and the UK, and this requires lots of care to make sure business is done in a suitable manner.

It is important to understand clients and their families as it’s not uncommon for US and UK families to move between countries during their lifetime.  We also see the children of our clients moving between both countries and they often have dual citizenship.

We often advise clients that it is not only important to get life insurance design correct for the grantor of a trust but also for the beneficiaries.  In many cases, our clients have life insurance designs that will allow them to live in either country without any adverse tax consequences or onerous reporting obligations.

JAY:   Let’s stick to this topic of multi-country planning.  If you have a client tell you they are planning to move to the U.S. where they will become a U.S. taxpayer, what are the pitfalls you typically plan for and how do you go about addressing them?

GRAYSON:  Having worked with many families who move to the US from the UK and other countries, it is important to start the process of discussing planning at least one year before a move to the US.  There are many pitfalls but also planning opportunities that clients may lose if not done before an official move. 

The main thing we see is life insurance that is purchased from the UK that is either non complaint under US law, or policies which are held in trusts in the UK, which will form part of the taxable estate in the US.

Cash value polices from the UK typically would not meet the tests under US law as life insurance.  These policies will likely have unfavorable taxation in the US; no policy loan features and taxable death benefits for residents of the US.

It is very important to start the process early as replacement of UK policies will likely require new US trusts being drafted and new underwriting of life insurance from the US market.

We will also do full reviews of other financial planning such as reviews of UK retirement plans and how they will be treated under the US/UK Double Tax Treaty.  Investment Portfolios could also be tax inefficient and a discussion on pre immigration trusts or partnerships should form part of the discussions.

JAY:  Last April, you witnessed a major tax law change in the U.K. that is causing a lot of disruption with high-net-worth clients.  Can you explain what happened and how life insurance might be able to help?  Also, am I correct in saying that private placement life insurance might play a role?

GRAYSON: The changes that happened in 2025 are more about how the new UK Labour Government has decided to tax its residents as opposed to changes in the life insurance industry.  The major announcement in 2025 was that the UK was going to abolish the resident/non domicile rules which had been around for over two hundred years.  These rules allowed UK non-domiciles to only pay taxes on UK sourced income.  The new rule changes have also limited trusts on how they protect against both income taxes and UK inheritance taxes.

Some additional changes are related to the tax relief that UK businesses and farms received on UK inheritance tax and new tax laws that can add a tail of up to ten years on inheritance taxes for those who decide to break residence and leave the UK.

For those affluent families who were being treated as non-domiciles in the UK and were not liable to income and gains on their foreign earnings and estates, new planning is needed to provide for both income tax and inheritance taxes. 

The UK only has an exemption of GBP 325,000 per individual from inheritance taxes whereas the US has an exemption on the first USD 15,000,000 per US citizen for this tax year.  Therefore, the need for life insurance planning in the UK for inheritance taxes has become more acute.  For PPLI planning, the ability to defer or eliminate income taxes for individuals and trust assets has become more of a discussion topic now than I have seen in the last thirty years.

JAY:  In the United States, I often hear life insurance producers complaining about having to take the Series 7 and 63 exams to be able to sell variable products.  Those exams would be in addition to the customary state licensing test.   If I understood what went into the qualifications you obtained in the U.K., the U.S. requirements seem rather light.  I would like to hear what the U.K. qualifications are, what led to their creation and what effect they have had on the U.K. life insurance marketplace.

GRAYSON:  To sell or advise retail clients on life insurance matters as they relate to cash value or investment policies, an advisor would need to hold a level four qualification in the UK.  Before the 31^st of December 2012, advisors only required a level two qualification, so the bar was raised quite considerably. 

As there was no grandfathering of this new qualification for licensed advisors, this forced many UK life insurance and investment advisors to now have to get requalified to stay licensed.  The level four qualification requires the passing of six different exams on subjects such as UK regulations, Investments, UK taxes, UK Life Insurance, Pension Planning and Financial Planning.  Very sadly these changes forced many older advisors into early retirement from the UK advisor market in 2012.

For US advisors who want to work in the UK market, the barrier to entry is quite high for professional exams as it would require all the US licensing and the UK exams/qualification to become dual qualified.

JAY:  Last June, I had dinner with you and your wife and co-worker, Karen, at the Royal Automobile Club in London.  You are a lovely couple, and I had a wonderful time.  How do the two of you spend your free time away from growing Vie International? 

GRAYSON: Thank you Jay!  Karen and I are the two main Directors at Vie International and spend a lot of time working together to run this business.  When we find time away from the business, we like to take full advantage of travel opportunities with Italy and Greece being two of our favorite places to travel.  London is also a wonderful place to work and play with the West End Theatres and London restaurants being great ways to spend time together outside of work.

JAY:  Thank you for participating in the Tier One Interview Series, Grayson.  You have reinforced why I always tell lawyers who reach out to me regarding dual U.S. and U.K. client situations to call you!   We have reached our increasingly popular restaurant question, and I know you have come prepared.  Without naming a steakhouse or a steak dish, give me some recommendations on where I should eat and what I should order when I am there.

GRAYSON: Given that I am a New Orleanian transplanted in London, I can’t help but throwing one of my favorites from both places.  Both are popular so make sure to book well in advance.

In New Orleans, you should visit Jacques – Imos and order the Jacques Duck and Andouille Gumbo with Potato Salad to start and the Crawfish Etouffee over rice for your mains.

In London, Kitty Fishers Mayfair, which is a small boutique restaurant, I would recommend The Norfolk Rabbit Croquettes & Chive Aioli to start and for the main course Harewood Estate Venison Loin, Turnips & Redcurrants.

---

 Since its inception, Life Insurance Strategies Group has solely focused on the individual high net worth life insurance market. We do not sell products. This allows us to offer unbiased, pragmatic advice. Visit us at www.lifeinsurancestrategiesgroup.com.

•