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In addition to what you said, doesn't the cash value in the VUL also get applied to the death benefit, if necessary?

So, you are saying there are two scenarios, insurance and captial accumulation. If I want insurance with tax-deferred capital accumulation, although at a slower rate, go with VUL. If I just want the tax-deferred capital accumulation, go with a VA.

When I pull the money out of either, I pay regular income tax. OTOH, if I die beforehand, the VUL death benefit is tax-free to my heirs.

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