ROLE OF LLCS IN TRUST AND ESTATE PLANNING
|
|
- Wilfred Higgins
- 5 years ago
- Views:
Transcription
1 ROLE OF LLCS IN TRUST AND ESTATE PLANNING First Run Broadcast: March 14, :00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) LLCs can be effective vehicles for achieving client goals in trust and estate planning. They are helpful particularly helpful in the context of transferring family-held businesses, from obtaining valuation discounts to succession planning and transfer of control. As income tax planning becomes more important in traditional trust and estate planning, LLCs also offer substantial opportunities for tax reduction. There are also substantial uses of LLCs in holding and transferring real estate, which often forms the most valuable asset in an estate. This program will provide you with a real world guide to using LLCs in your trust and estate planning practice. Use of LLCs for business succession planning purposes Family LLCs and LPs practical uses and risks of IRS challenge Rising importance of income tax planning opportunities Issues involved in holding real estate Impact of new tax law Valuation discount planning when using LLCs and spotting red flags for IRS challenge Speakers: William Kalish is a partner in the Tampa office of Johnson Pope Bokor Ruppel & Burns, LLP. His practice focuses on advising individual clients and their families on their estate and trust plans, including wills, revocable trusts, irrevocable trusts, charitable trusts, private foundations, and limited partnerships. He also practices in probate administration, asset preservation, business succession planning for family-owned entities, and the division of business interests in the context of divorce. He is a Fellow of the American College of Tax Counsel, formerly served as chair of Administrative Practice Committee of the ABA Tax Section, and has served as an Adjunct Professor of Law at Stetson Law School teaching estate planning. Mr. Kalish received his B.A. from the University of Pittsburg and his J.D. with honors from George Washington University Law School. Jeffrey M. Gad is a partner in the Tampa, Florida office of Johnson Pope Bokor Ruppel & Burns, LLP, where his practice emphasizes representing individuals emphasizing a broad range of probate, business and taxation related issues. His practice integrates the personal and estate tax planning concerns of individuals with tax and business planning for their closely-held businesses. He has extensive experience in all aspects of probate and trust administration, including the preparation of estate tax returns. Mr. Gad earned his B.S.B.A. from the University of Florida, his J.D., magna cum laude, from Nova Southeastern University, Shepard Broad Law Center, and his LLM from New York University School of Law.
2 VT Bar Association Continuing Legal Education Registration Form Please complete all of the requested information, print this application, and fax with credit info or mail it with payment to: Vermont Bar Association, PO Box 100, Montpelier, VT Fax: (802) PLEASE USE ONE REGISTRATION FORM PER PERSON. First Name Middle Initial Last Name Firm/Organization Address City State ZIP Code Phone # Fax # Address Role of LLCs in Trust & Estate Planning Teleseminar March 14, :00PM 2:00PM 1.0 MCLE GENERAL CREDITS VBA Members $75 Non-VBA Members $115 NO REFUNDS AFTER March 7, 2018 PAYMENT METHOD: Check enclosed (made payable to Vermont Bar Association) Amount: Credit Card (American Express, Discover, Visa or Mastercard) Credit Card # Exp. Date Cardholder:
3 Vermont Bar Association CERTIFICATE OF ATTENDANCE Please note: This form is for your records in the event you are audited Sponsor: Vermont Bar Association Date: March 14, 2018 Seminar Title: Location: Credits: Program Minutes: Role of LLCs in Trust & Estate Planning Teleseminar - LIVE 1.0 MCLE General Credit 60 General Luncheon addresses, business meetings, receptions are not to be included in the computation of credit. This form denotes full attendance. If you arrive late or leave prior to the program ending time, it is your responsibility to adjust CLE hours accordingly.
4 Family Business Succession Planning, the New Tax Act, and Asset Protection Daniel L. Daniels Wiggin and Dana
5 Introduction General Challenges Estate tax uncertainty Planning must be done on short time frame Business is valuable, but often illiquid, asset Business owners can be challenging clients Creating a Succession Plan Which: Passes the business to intended owners Doesn t adversely affect the business Doesn t treat anyone unfairly 2
6 Same Family Business Succession Statistics - 90% of U.S. businesses are family firms - Represent 64% of Gross Domestic Product - Only one-third make the successful transition to the second generation - Only 15% make it to the third generation - Recent studies indicate 25% will transfer control over the next 5 years (40% over 10 years) - 71% have not completed business succession plans - 93% have little income diversification outside the business - 80% want business to stay in family 3
7 Family Dynamics - Family dynamics issues more important than proper estate tax planning to future success of business. - Choice of successor manager - Active vs. inactive family members - Separating management structures from ownership structures - Intergenerational communications - Providing equally for children - Cash flow concerns of senior generation - Conflict Management and Dispute Resolution - Role of professional facilitators 4
8 Fact Pattern Family Information Client and Spouse, age 65 Client has three children, A, B and C A active in business; B and C are not A is married, but not happily B and C are both married with children 5
9 Fact Pattern Business Information Client is 90% owner of XYZ Inc., an S corporation A, B and C each own 3.33% XYZ s primary business is commercial real estate Company book value is $20 million Company owns $2 million of insurance on Client s life Company leases its headquarters building and premises from Client 6
10 Fact Pattern Other Assets Client owns headquarters building valued at $1 million Client and spouse jointly own principal residence worth $3 million and vacation residence worth $1 million Client has IRA worth $2 million Client and spouse have joint brokerage account worth $3 million Client owns life insurance policy of $2 million 7
11 Fact Pattern Current Estate Planning Documents Client and spouse each have wills leaving entire estates to each other, then to the children Planning Objectives Keep the non-active children (B and C) out of the business Pass control of the business to A Treat A, B and C equally financially Pay as little estate taxes as possible Avoid forced sale of business at death Minimize probate Minimize liabilities 8
12 Phase One Planning 9
13 Phase One Planning (Review) Testamentary documents (will and revocable trust) Defensive tax planning Powers of attorney Health care proxies Life insurance (even if temporary) to deal with liquidity issues pending results of Phase Two planning Buy-sell agreement 10
14 PHASE TWO PLANNING The new tax law Choice of entity Asset protection Advanced Lifetime Gift Planning Advanced Testamentary Planning Charitable Strategies 11
15 2017 Tax Act Transfer Tax Provisions Increased estate, gift and generation skipping tax exemptions to $11.2 million, indexed for inflation Only in effect until January 1, 2026 Retains 40 percent rate Retains unlimited marital deduction 12
16 2017 Tax Act Selected Corporate Income Tax Provisions C Corporations Flat corporate income tax rate of 21 percent Corporate AMT repealed Does not sunset 13
17 2017 Tax Act Selected Corporate Income Tax Provisions Pass-Through Entities Deduction equal to 20 percent of qualified business income BUT deduction limited to the greater of: 50 percent of taxpayer s allocable share of W-2 wages for the entity OR 25 percent of taxpayer s allocable share of W-2 wages plus 2.5 percent of depreciable property in service 14
18 2017 Tax Act Selected Corporate Income Tax Provisions Pass-Through Entities (2) Qualified business income is income earned from a trade or business Income from most service businesses doesn t count to the extent it exceeds certain thresholds $315,000 for married couples $157,500 for singles Service businesses include health, law, accounting, consulting, actuarial science, performing arts, athletics, financial services, brokerage services, reputation-based services and investment management Architecture and engineering service business income DOES count Pass through entity provisions expire January 1,
19 ENTITY-LEVEL PLANNING Choice of entity C corporation now receives highly advantageous income tax rate but is highly undesirable at death LLC or LP produces best basis step up flexibility Synthetic basis step up may be available for S corporation inside assets if corporation liquidated after death Consider dividing stock between spouses for Mellinger discount Consider voting-nonvoting recap to allow for transfer of value but not control to inactive children Consider moving real estate out of corporation into LLC for asset protection purposes 16
20 ASSET PROTECTION Exemption Planning Asset Transfer Planning Family Partnership or LLC Planning On- and Off-shore Trusts 17
21 Overview: Sources of Liability Fiduciary positions Example: directors of public companies Contract Example: personal guarantee of business loan Tort Example: professional malpractice Family Example: divorce 18
22 Overview: Two Prongs of Planning Two basic planning concepts: Limitation of Liability Asset Protection 19
23 Limitation of Liability Inside-out protection. Attempt to trap liabilities within an entity. Prototype is parent-subsidiary (or owner-company) structure. 20
24 Limitation of Liability Parent/Owner Subsidiary/ Company 21
25 Asset Protection Outside-in protection Take advantage of exemptions Separate assets from source of liability Hold assets in a protected form No silver bullet Planning is generally a process of discounting settlement of creditors claims 22
26 Exempt Assets Homestead? Life insurance? Primarily retirement assets 401(k) plans Roth IRAs Traditional IRAs 23
27 Separating Assets Separating assets means client must transfer assets. Transfer will be subject to scrutiny and may be voided as fraudulent conveyance. 24
28 Separating Assets: Examples Gift to spouse Simple Often beneficial for general estate planning purposes No tax impact unless spouse is non-u.s. citizen Gift to children Can have estate planning benefits May generate gift tax Gift to trust for spouse and/or children Consider Spousal Estate Reduction Trust Gift to trust for self generally not effective Consider off-shore or special U.S. jurisdictions? 25
29 FLPs and Other Protected Assets Charging order entities. Other illiquid assets. Encumbered assets. 26
30 Charging Orders Creditors cannot force the sale of certain types of entities (partnerships and their LLC relatives). Step into the shoes of the debtorpartner and wait until the management of the partnership decides to make distributions to the partners. 27
31 Charging Orders A charging order is a remedy created by statute which essentially assigns the debtor s interest in a partnership or limited liability company to the creditor. As an assignee, the creditor is not entitled to become a limited partner, and has no ability to dissolve the entity. 28
32 On- and Off-shore Asset Protection Trusts Have your cake and eat it too? Transfers to self-settled trust allow transferor to divest self of title, but still have beneficial interest. Self-settled trusts not recognized at common law. Statute of Elizabeth. Restatement (Second) of Trusts, 156. Greenwich Trust Co. v. Tyson, 129 Conn. 211 (1942). Some jurisdictions have changed this by statute. 29
33 On-shore Asset Protection Trusts Several US states now permit self-settled trusts to some degree: Alaska, Delaware, South Dakota. Untested problems with these protections. Full Faith and Credit Clause of Const. 30
34 APPLYING CREDITOR PROTECTION CONCEPTS TO CHARLIE AND SALLY S SITUATION Be sure to respect the form of the entity Segregate separate parcels into separate entities Consider Master LLC with subsidiary for each parcel Consider spendthrift trust for Abby 31
35 LIFETIME GIFTING FUNDAMENTALS Gifts valued at time of gift Avoid tax on future growth and income Defer tax on applicable exclusion amount Valuation opportunities Property without clear value Discounted gift tax value Choice of property to gift Should be likely to appreciate Avoid tax on gift tax Beware: loss of basis step-up at death 2018 Wiggin and Dana 32
36 Lifetime Gift Strategies Outright Gifts To spouse to create discounts applicable exclusion amount Annual exclusion Taxable gifts Spousal Lifetime Access Trust Grantor Retained Annuity Trust Preferred/Common Recap Gifts Caveat: Recapitalization must comply with section 2701 Opportunity Shifting 2018 Wiggin and Dana 33
37 A Zeroed Out GRAT Grantor transfers $1 million to a GRAT when IRS assumed interest rate = 1.4% Grantor receives $119,000 annually for 9 years After 9 years, remaining GRAT funds pass to children Value of taxable gift is near $ Wiggin and Dana 34
38 Savings Dependent On Investment Performance Average Return for 9 years Amount Passing Tax-Free to Children After 9 Years 1.4% $0 4% $164,000 6% $322,000 8% $513, Wiggin and Dana 35
39 Property Suitable for a GRAT Growth stocks Commercial real estate Closely held business LLCs and LPs Gift tax risk of undervaluation can be minimized 2018 Wiggin and Dana 36
40 GRAT Risks What if grantor dies before termination of GRAT? At worst, property is taxable in grantor s estate Nothing gained, but nothing lost What if trust investment performance is less than IRS assumed rate of return? Again, nothing gained, but nothing lost 2018 Wiggin and Dana 37
41 Sale to an Intentionally Defective Irrevocable Trust (IDIT Sale) Grantor Sells Property to Irrevocable Grantor Trust Grantor Receives Promissory Note From Trust Note Terms Interest Only at Applicable Section 1274 Rate Balloon Payment of Principal at End of Note Term Grantor s Interest in Property Frozen at Face Value of Note Plus Annual Interest Payments Objective: Outperform Required Interest Rate On Note Under Section Wiggin and Dana 38
42 IDIT Sale Example Grantor Sells Property Worth $1,000,000 to Seeded Irrevocable Grantor Trust Grantor Receives 9-Year Promissory Note From Trust Note Terms Interest Only at Applicable Section 1274 Rate (1.20% for this example) Balloon Payment of Principal at End of Note Term 2018 Wiggin and Dana 39
43 Amount to Children Depends on Investment Performance Average Return for 9 years Amount Passing Tax-Free to Children After 9 Years 1.2% $ 0 1.4% $ 19,000 4% $296,000 6% $552,000 8% $849, Wiggin and Dana 40
44 IDIT Sale Risks No Safe Harbor Under Code No Automatic Revaluation of Note Upon Audit Will formula work to avoid Proctor? Possible Application of Sections 2036 and 2702 Statute of Limitations Possible Gain Recognition At Grantor s Death 2018 Wiggin and Dana 41
45 Self-Canceling Installment Note (SCIN) By its terms note is extinguished on Client s death Note must take possibility of death into account in form of risk premium Increased interest rate or increased principal amount No safe harbor for valuation; IRS will look at client s actual health status. Note is excluded from Client s estate Client s estate recognizes unrealized gain at death 42
46 SCIN Example Client sells $1,000,000 asset to A in return for selfcanceling note Interest only for 9 years; balloon principal at end of year 9 Note interest rate includes risk premium so that rate increases from 4.82% to 6.98% Or increase principal face amount to $1,181,000 Client receives payments of $69,800 per year Balloon payment of $1,000,000 at end of year 9 43
47 SCIN: Amount to Children Depends on Investment Performance Average Return for 10 years Amount Passing Tax-Free to Children After 10 Years 6.98% $0 8% $138,000 10% $451,000 12% $831,000 14% $1,287,000 44
48 Private Annuity Client transfers stock to A in return for A s agreement to pay an annuity for remainder of A s lifetime Advantages to Client Estate freeze at value of annuity payments plus internal interest rate. No gift tax provided that annuity value equals value of transferred stock. Income stream guaranteed for life Advantages to A Cash flow Windfall in the event Client dies early 45
49 Private Annuity (Continued) Disadvantages Regulations on income tax treatment of the annuity. If stock is undervalued, Client will be treated as having made a taxable gift. A price adjustment clause may not be respected. A s payments are indefinite and nondeductible. 46
50 BOOTSTRAP REDEMPTION Client gifts small amount of stock to A Corporation redeems Client s stock, thereby increasing A s ownership percentage Caveat: Since B and C, and key employees own shares as well, their ownership percentages will also be increased 47
51 Selected Charitable Options 48
52 The Typical Charitable Vehicles Private Foundations Charitable Lead Trusts Charitable Remainder Trusts 49
53 Private Family Foundation Default Status - Greatest Donor Control 3 Typical Characteristics: single source of funding make grants rather than operate programs grants and administrative expenses paid from endowment Subject to Chapter 42 Excise Tax Rules unavoidable: tax on net investment income avoidable: self-dealing, failure to distribute income, excess business holdings, jeopardy investments and taxable expenditure 5% Mandatory Annual Distributions 50
54 Charitable Remainder Trust Irrevocable trust Income stream payable to one or more noncharitable beneficiaries For life or for a fixed term Remainder interest payable to charity 51
55 Charitable Remainder Trust Trust pays no income tax Tax-free diversification vehicle Grantor gets estate, gift and income tax deductions Increased cash flow Income deferral (NIMCRUT) Closely held business assets (FLIPCRUT) 52
56 Charitable Lead Trust Charitable remainder trust in reverse Lead Interest - annuity or unitrust to charity Term Remainder interest to grantor or family Income tax deductibility limited to grantor trusts only Income taxation of trust depends on structure Non-grantor trusts taxed as complex trust with 642(c) deduction for payments to charity Grantor trust taxed under traditional rules 53
57 Overview of Tax Issues Private Foundation Excise Taxes Self-dealing and excess business holdings are primary concern Unrelated Business Income Tax ( UBIT ) Prearranged Sale Ascertainability Other Tax Issues 54
58 Entities Subject to Excise Taxes Private Foundations Subject to all taxes Charitable Lead Trusts Subject to taxes on self-dealing, excess business holdings, jeopardy investments and taxable expenditures CLTs are subject to taxes on excess business holdings or jeopardy investments if value of the charitable interest exceeds 60% CLTs are not subject to the minimum distribution tax or the net investment income tax Charitable Remainder Trusts Subject only taxes on self-dealing and taxable expenditures 55
59 Self Dealing Most transactions between a private foundation and a disqualified person are strictly prohibited regardless of whether the transaction is beneficial to the foundation Example: Use of foundation to satisfy charitable pledge Tax rates 10% initial tax 200% tax if act not corrected within prescribed period Indirect self dealing The general redemption exception 56
60 Excess Business Holdings Excess business holdings occur when holdings of foundation plus disqualified persons exceed 20% Increased to 35% if effective control of the business is held by non-disqualified persons Does not apply to business receiving 95% or more of income from passive sources 2% de minimis rule Foundation has five years to dispose of excess business holdings Up to additional five years with permission of IRS Tax rate: 10% of value of holdings Rate increased to 200% if not corrected in timely manner 57
61 Unrelated Business Taxable Income General Rule: Charities Exempt from Federal Income Tax Exception: Charities Taxable on Unrelated Business Taxable Income ( UBTI ) UBTI Defined: Income from an Active Trade or Business Excludes Passive Investments (unless Debt-financed) Example of Debt-financed Passive Income Mortgaged real estate Tax only imposed on debt-financed portion of income and gain Prior to 1/1/2007, A CRT lost its tax exempt status in any year that it had UBTI Post 1/1/2007, no loss of exempt status but rather 100% excise tax on any UBTI 58
62 The Prearranged Sale Problem If Foundation or CRT enters into informal agreement to sell property prior to contribution, then IRS may recharacterize transaction as a sale by grantor personally Causes grantor to be taxed personally on sale Cases and rulings favorable to taxpayer Palmer v. Commissioner Rev. Rul Rauenhorst v. Commissioner Cases favorable to IRS Blake v. Commissioner Ferguson v. Commissioner 59
63 The Ascertainability Problem To qualify for charitable deduction value of bequest must be presently ascertainable as of date of death The Marine case Decedent s will left residuary estate to charity Will gave executor discretion to make preresiduary gifts to various individuals of up to 1% of the estate per individual Estate tax charitable deduction denied because executor s discretion made value of residuary estate unascertainable Note, a beneficiary s power to choose between two different charitable lead trusts did not fail the Marine test PLR
64 Testamentary Charitable Planning Simple Bequest of the Business to a Private Foundation Bequest to Private Foundation Followed by a Redemption Bequest to Private Foundation Coupled with an Option Bequest to a Charitable Lead Trust Coupled 61
65 Simple Bequest to Private Foundation Perceived Benefits Eliminates estate tax on the business at death Preserves owner s control Preserves family control as Trustees of Foundation Tax Issues Typically Make the Simple Bequest Untenable Excess business holdings Self-dealing Indirect self-dealing UBIT S corporation concerns Solution: Get the Business Out of the Foundation How 62
66 The General Redemption Exception Simple sale of business to family member causes self-dealing problem Redemption must be: At fair market value All cash Offered to all owners of same class of stock Structuring the Estate Plan with the Exception in Mind: Prior to death, recapitalize business into separate classes of stock Class A held or bequeathed to family members Class B bequeathed to Foundation Corporation redeems Class B stock from Foundation Beware charitable deduction valuation whipsaw 63
67 Bequest to Foundation Coupled with an Option Alternative to General Redemption Technique Decedent bequeaths business to Foundation subject to option in family to purchase from the estate for fair value Sale will not constitute self-dealing if requirements of Treas. Regs. sec (d)-1(c) are met Sale for fair market value Court approval Completed during reasonable period of estate administration 64
68 Benefits and Risks of Option/Note Benefits Technique Avoids problems presented by simple bequest Unlike general redemption exception, IRS has approved use of a disqualified person s note to fund the purchase price Concerns/Risks Terms of note must be fair Court approval required Payments under note must be timely made Refinancing of note probably constitutes self-dealing All payments on the note inure to benefit of Foundation 65
69 Bequest to CLAT Coupled with an Option Alternative to Foundation/Note Technique Similar Benefits and Risks Additional Benefit: Decedent s Family Receives CLAT Remainder Additional Concerns CLAT payments should be set to correspond to cash flow from business Ascertainability issues if CLAT design set by formula or if multiple CLATs are used Possible generation-skipping tax if CLAT rather than CLUT is used 66
70 Bequest to CLAT Coupled with an Option: Example C owns commercial real estate business with NAV of $100 million Business produces annual cash flow of $8 million Assume 30% valuation discount C bequeaths business to CLAT subject to option in children to purchase from estate for fair market value using promissory note Assume section 7520 rate of 5.4% 67
71 Bequest to CLAT Coupled with an Option: Example (Continued) $70 million CLAT with lead payment of roughly $7.6 million zeroes out with a 13 year term Note structured with interest rate of 5.4% amortizes at annual payment of approximately $7.6 million in 13 years At end of CLAT term Note is fully paid CLAT has minimal remainder interest Children receive business free and clear of note 68
72 Bequest to CLAT Coupled with an Option: Payout rate Term Issues to Consider What if cash flow from business is less than anticipated or Trustee is concerned that planned-for valuation discounts may not materialize? Consider giving Trustee power to choose among CLATs with varying payout rates Draft trust to last for a sufficient term to produce an estate tax charitable deduction equal to the value of the assets passing to the trust Promissory note Set note term equal to term of CLAT Set interest rate at or above section 7520 rate Provide for security 69
73 Bequest to CLAT Coupled with an Option: Issues to Consider CLAT remainder beneficiaries Ensure remainder beneficiaries are identical to payors on the promissory note Consider guarantees/personal liability if necessary to support valuation of note Consider trust structure to defer application of generation-skipping transfer tax and provide management and creditor protection 70
74 Contact Information Daniel L. Daniels, Esq. Wiggin and Dana LLP 30 Milbank Avenue Greenwich, CT
Day 1 March 26, 2015:
PLANNING IN CHARITABLE GIVING, PART 1 & PART 2 First Run Broadcast: August 19 & 20, 2014 Live Replay: March 26 & 27, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Charitable
More informationBUSINESS SUCCESSION PLANNING FOR ESTATE PLANNERS
BUSINESS SUCCESSION PLANNING FOR ESTATE PLANNERS First Run Broadcast: October 26, 2016 Live Replay: June 1, 2017 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) One of the biggest
More informationLIQUIDITY PLANNING IN ESTATES AND TRUSTS
LIQUIDITY PLANNING IN ESTATES AND TRUSTS First Run Broadcast: February 8, 2013 Live Replay: June 10, 2013 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Obtaining liquidity
More informationPLANNING WITH GRATS First Run Broadcast: August 1, :00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T.
PLANNING WITH GRATS First Run Broadcast: August 1, 2017 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) GRATs, or Grantor Retained Annuity Trusts, are one of the most effective
More informationTRUST AND ESTATE PLANNING WITH LIFE INSURANCE
TRUST AND ESTATE PLANNING WITH LIFE INSURANCE First Run Broadcast: September 7, 2017 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Life insurance trusts are platforms to transfer
More informationESTATE PLANNING FOR GUARDIANSHIP AND CONSERVATORSHIPS
ESTATE PLANNING FOR GUARDIANSHIP AND CONSERVATORSHIPS First Run Broadcast: August 25, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Use of conservatorships and guardianships
More information"CRUMMEY POWERS": DRAFTING & USING THESE ESSENTIAL ESTATE PLANNING POWERS
"CRUMMEY POWERS": DRAFTING & USING THESE ESSENTIAL ESTATE PLANNING POWERS First Run Broadcast: July 6, 2017 Live Replay: May 14, 2018 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60
More informationSETTLEMENT AGREEMENTS IN ESTATE & PROBATE DISPUTES
SETTLEMENT AGREEMENTS IN ESTATE & PROBATE DISPUTES First Run Broadcast: November 12, 2015 Live Replay: July 6, 2016 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Money and
More informationPLANNING WITH LIFE INSURANCE TRUSTS First Run Broadcast: July 2, :00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T.
PLANNING WITH LIFE INSURANCE TRUSTS First Run Broadcast: July 2, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Life insurance trusts are effective mechanisms for transferring
More informationESTATE PLANNING FOR PORTABILITY First Run Broadcast: January 21, :00 p.m. E.T./1:00 p.m. C.T./12:00 p.m. M.T./11:00 a.m. P.T.
ESTATE PLANNING FOR PORTABILITY First Run Broadcast: January 21, 2016 2:00 p.m. E.T./1:00 p.m. C.T./12:00 p.m. M.T./11:00 a.m. P.T. (60 minutes) Portability, a relatively new concept in estate planning,
More informationDEFINED VALUE CLAUSES: DRAFTING & AVOIDING RED FLAGS
DEFINED VALUE CLAUSES: DRAFTING & AVOIDING RED FLAGS First Run Broadcast: April 26, 2018 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Formula and defined value clauses are
More informationA Gift for All Seasons: Matching Planned Giving Alternatives to Donor Objectives. 41st Annual MPGC Conference November 15-16, 2017
A Gift for All Seasons: Matching Planned Giving Alternatives to Donor Objectives 41st Annual MPGC Conference November 15-16, 2017 by Sheryl G. Morrison GRAY, PLANT, MOOTY, MOOTY & BENNETT, P.A. 500 IDS
More informationESTATE & TRUST PLANNING WITH THE NEW 3.8% TAX ON NET INVESTMENT INCOME
ESTATE & TRUST PLANNING WITH THE NEW 3.8% TAX ON NET INVESTMENT INCOME First Run Broadcast: September 1, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) The new 3.8% tax
More informationESTATE PLANNING AND IRAS First Run Broadcast: November 12, :00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T.
ESTATE PLANNING AND IRAS First Run Broadcast: November 12, 2013 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Liquid assets held in individual or employer sponsored qualified
More informationDay 1 October 21, 2015:
BUSINESS PLANNING WITH S CORPS, PART 1 & PART 2 First Run Broadcast: October 21 & 22, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes each day) This program will provide
More informationHOLDING BUSINESS INTERESTS IN TRUSTS First Run Broadcast: June 21, :00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T.
HOLDING BUSINESS INTERESTS IN TRUSTS First Run Broadcast: June 21, 2018 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) There are tax and other benefits to holding a closely-held
More informationBUY-SELL AGREEMENTS, PART 1 & PART
BUY-SELL AGREEMENTS, PART 1 & PART 2 First Run Broadcast: June 21 & 22, 2016 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes each day) There is rarely a liquid market for the
More informationSTRUCTURING FOR-PROFIT/NON-PROFIT JOINT VENTURES
STRUCTURING FOR-PROFIT/NON-PROFIT JOINT VENTURES First Run Broadcast: March 28, 2018 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Nonprofit organizations frequently partner
More informationINCOME AND FIDUCIARY TAX ISSUES FOR ESTATE PLANNERS, PART 1 & PART
INCOME AND FIDUCIARY TAX ISSUES FOR ESTATE PLANNERS, PART 1 & PART 2 First Run Broadcast: September 19 & 20, 2018 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes each day) Understanding
More informationSOPHISTICATED CHOICE OF ENTITY, PART 1 & PART
SOPHISTICATED CHOICE OF ENTITY, PART 1 & PART 2 First Run Broadcast: February 20 & 21, 2018 1PM EDT, 12PM CDT, 11AM MDT, 10AM PDT (60 minutes each day) Choosing the right entity for a closely-held business
More informationHow To Coordinate Charitable Contribution Planning Opportunities with Business Succession Planning: The Charitable Lead Trust
How To Coordinate Charitable Contribution Planning Opportunities with Business Succession Planning: The Charitable Lead Trust Michael V. Bourland Shannon G. Guthrie All section references are to the Internal
More informationUsing Your Assets to Promote your Values. Lawrence M. Lehmann, JD, AEP, CAP Lehmann Norman & Marcus LC
Using Your Assets to Promote your Values, JD, AEP, CAP Lehmann Norman & Marcus LC Charitable Motivation. The primary reason for charitable giving comes from the human heart. Unless the spark of philanthropy
More informationDay 1 August 23, 2018:
PLANNING WITH THE GENERATION SKIPPING TRANSFER TAX, PART 1 & PART 2 First Run Broadcast: October 26 & 27, 2017 Live Replay: August 23 & 24, 2018 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m.
More informationCharitable Lead Trusts in the New Tax Landscape
Charitable Lead Trusts in the New Tax Landscape Northern California Planned Giving Planned Giving Conference May 4, 2018 Vivian U. Redsar, Esq. Manatt, Phelps & Phillips, LLP Sarah Copeland Jordan Park
More informationThe Time is Right To Consider Charitable Lead Trusts
The Time is Right To Consider Charitable Lead Trusts May 13, 2016 2016 Day Pitney LLP Planned Giving Group of New England Jennifer M. Pagnillo, Esq. Day Pitney LLP 24 Field Point Road Greenwich, CT 06830
More informationINNOCENT SPOUSE DEFENSE
INNOCENT SPOUSE DEFENSE First Run Broadcast: August 21, 2012 Live Replay: August 16, 2013 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) When a married couple files its tax
More information2014 NONPROFIT LAW/EXEMPT ORGANIZATIONS UPDATE
2014 NONPROFIT LAW/EXEMPT ORGANIZATIONS UPDATE First Run Broadcast: January 9, 2014 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Nonprofit and exempt organizations are subject
More informationCharitable Giving: Tax Benefits and Strategies
Charitable Giving: Tax Benefits and Strategies CPAs Attorneys Enrolled Agents Tax Professionals Professional Education Network TM Contents 1 Introduction 2 Overview of Tax Benefits 3 Tax Treatment of Gifts
More informationHELD BUSINESS INTERESTS
PLANNED GIVING WITH CLOSELY HELD BUSINESS INTERESTS Gregory S. Williams, Esq. Carruthers & Roth, P.A. Phone: 336-478-1183 E-mail: gsw@crlaw.com Disclaimer The contents of this presentation have been prepared
More informationEstate Planning for Small Business Owners
Estate Planning for Small Business Owners HOSTED BY OCEAN FIRST BANK PRESENTED BY MONZO CATANESE HILLEGASS, P.C. SPEAKER: DANIEL S. REEVES, ESQUIRE Topics Tax Overview Trust Ownership Intentionally Defective
More informationANITA J. SIEGEL, ESQ. Siegel & Bergman, LLC 365 South Street Morristown, NJ Fax
ANITA J. SIEGEL, ESQ. Siegel & Bergman, LLC 365 South Street Morristown, NJ 07960 973-285-5007 Fax 973-285-5008 ajs@sblawllc.com CHARITABLE PLANNING A PRIMER April 4, 2011 Planning for charitable gifts
More informationPRACTICAL TIPS FOR CHARITABLE PLANNING
PRACTICAL TIPS FOR CHARITABLE PLANNING CLINT T. SWANSON SWANSON LAW FIRM, PLLC 200 REUNION CENTER NINE EAST FOURTH STREET TULSA, OKLAHOMA 74103 I. CHARITABLE PLANNING A. Importance of Charitable Planning
More informationTHE SCIENCE OF GIFT GIVING After the Tax Relief Act. Presented by Edward Perkins JD, LLM (Tax), CPA
THE SCIENCE OF GIFT GIVING After the Tax Relief Act Presented by Edward Perkins JD, LLM (Tax), CPA THE SCIENCE OF GIFT GIVING AFTER THE TAX RELIEF ACT AN ESTATE PLANNING UPDATE Written and Presented by
More informationnumer cal anal ysi shown, esul nei her guar ant ees nor ect ons, and act ual esul may gni cant Any assumpt ons est es, on, her val ues hypot het cal
Table of Contents Disclaimer Notice... 1 Disclosure Notice... 2 Charitable Gift Annuity (CGA)... 3 Charitable Giving Techniques... 4 Charitable Lead Annuity Trust (CLAT)... 5 Charitable Lead Unitrust (CLUT)...
More informationEstate planning for non-citizens.
Estate Planning Estate planning for non-citizens. The federal gift and estate tax laws that apply to non-united States citizens (aliens) are different from those for citizens. Further, there are different
More informationCharitable Planning Opportunities
Charitable Planning Opportunities Case Study Examples Written and Presented by Michael V. Bourland Bourland, Wall & Wenzel, A Professional Corporation Attorneys and Counselors 301 Commerce Street, Suite
More informationHERMENZE & MARCANTONIO LLC ADVANCED ESTATE PLANNING TECHNIQUES
HERMENZE & MARCANTONIO LLC ADVANCED ESTATE PLANNING TECHNIQUES - 2019 I. Overview of federal, Connecticut, and New York estate and gift taxes. A. Federal 1. 40% tax rate. 2. Unlimited estate and gift tax
More informationComprehensive Charitable Planning
CLIENT GUIDE Advanced Markets Comprehensive Charitable Planning John Hancock Life Insurance Company (U.S.A.) (John Hancock) John Hancock Life Insurance Company of New York (John Hancock) LIFE-5175 1/17
More informationGST and Form 709: Fundamentals of Generation-Skipping Transfer Tax Reporting
GST and Form 709: Fundamentals of Generation-Skipping Transfer Tax Reporting FOR LIVE PROGRAM ONLY THURSDAY, DECEMBER 20, 2018, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR THE LIVE PROGRAM This program
More informationTHE DESIGN, FUNDING, ADMINISTRATION & REPAIR OF GRATS, QPRTS & SALES TO IDGTS
THE DESIGN, FUNDING, ADMINISTRATION & REPAIR OF GRATS, QPRTS & SALES TO IDGTS The Estate Planning Council of Greater Miami October 20, 2016 Louis Nostro, Esquire Nostro Jones, P.A. Miami, Florida lnostro@nostrojones.com
More informationCharitable Planning in a New Era
Charitable Planning in a New Era Karen E. Yates LeClairRyan New Haven, CT Constance Shields Withers Bergman LLP New Haven, CT NEGASC, June, 2017 Why Give? (And Why Planned Giving?) What Motivates? o Relationships
More informationTHE ESTATE PLANNER S SIX PACK
Tenth Floor Columbia Center 101 West Big Beaver Road Troy, Michigan 48084-5280 (248) 457-7000 Fax (248) 457-7219 SPECIAL REPORT www.disinherit-irs.com For persons with taxable estates, there is an assortment
More informationTransferring the Family Business
Transferring the Family Business Inside this issue I. Introduction II. Primary Objectives III. Ways to Shift Control Bequest Gift Sale o Sale to Defective Grantor Trust o Using a SCIN o Private Annuity
More informationContents PERSONAL FINANCE HEALTH AND MEDICAL
Contents PERSONAL FINANCE Financial Planning Issues The Financial Planning Puzzle...1 The Need for Financial Planning...2 Basic Steps in the Financial Planning Process...4 Choose the Financial Planning
More informationEstate Planning Client Guide
CLIENT GUIDE Advanced Markets Estate Planning Client Guide LIFE-5711 6/17 TABLE OF CONTENTS Why Create an Estate Plan?... 1 Basic Estate Planning Tools... 2 Funding an Irrevocable Life Insurance Trust
More informationWealth Transfer and Charitable Planning Strategies. Handbook
Wealth Transfer and Charitable Planning Strategies Handbook Wealth Transfer and Charitable Planning Strategies Handbook This handbook contains 12 core wealth transfer and charitable planning strategies.
More informationCreates the trust. Holds legal title to the trust property and administers the trust. Benefits from the trust.
WEALTH STRATEGIES THE PRUDENTIAL INSURANCE COMPANY OF AMERICA Understanding the Uses of Trusts WEALTH TRANSFER OVERVIEW. The purpose of this brochure is to provide a general discussion of basic trust principles.
More informationReporting GRATS, GRUTS, ILITS and IDGTs on Form 709: GST Exemption Allocation Calculations and Strategies
FOR LIVE PROGRAM ONLY Reporting GRATS, GRUTS, ILITS and IDGTs on Form 709: GST Exemption Allocation Calculations and Strategies WEDNESDAY, JULY 13, 2016, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationEffective Strategies for Wealth Transfer
Effective Strategies for Wealth Transfer The Prudential Insurance Company of America, Newark, NJ. 0265295-00002-00 Ed. 02/2016 Exp. 08/04/2017 UNDERSTANDING WEALTH TRANSFER What strategy to use and when?
More informationPRACTICAL CHARITABLE PLANNING EXAMPLES THAT DON T REQUIRE YOU TO BE A TAX EXPERT. THE ABCS OF CRATS, CRUTS, CLATS AND CLUTS.
PRACTICAL CHARITABLE PLANNING EXAMPLES THAT DON T REQUIRE YOU TO BE A TAX EXPERT. THE ABCS OF CRATS, CRUTS, CLATS AND CLUTS. IS THE ALPHABET REALLY THAT DIFFICULT? HOW TO PROVIDE FOR YOUR FURRY FRIENDS!
More informationTABLE OF CONTENTS. Page
TABLE OF CONTENTS Page I. PERIOD OF OPPORTUNITY... 1 A. Renewed Interest in Charitable Lead Trusts... 1 B. Opportunities for Charities... 2 II. CHARITABLE LEAD TRUSTS THE FUNDAMENTALS... 2 A. A Working
More informationMemorandum FILE. Naim D. Bulbulia, Esq. Estate Planning Primer
Memorandum TO FROM FILE Naim D. Bulbulia, Esq. DATE May 5, 2005 RE Estate Planning Primer The following memorandum has been prepared in order to provide you with an overview of estate and gift tax law
More informationEstate Planning. Insight on. The Crummey trust: Still relevant after all these years. Now s the time for a charitable lead trust
Insight on Estate Planning October/November 2014 The Crummey trust: Still relevant after all these years Now s the time for a charitable lead trust Good intentions Don t let asset transfers run afoul of
More information11/9/2012. Estate and Charitable Planning Before the End of IRS Circular 230. Historical Estate Tax Rates and Exemptions
Estate and Charitable Planning Before the End of 2012 SOL S. REIFER, J.D., LL.M. KYLE C. POST, J.D., LL.M. WRIGHT GINSBERG BRUSILOW P.C. 14755 PRESTON ROAD, SUITE 600 DALLAS, TEXAS 75254 972-788-1600 sreifer@wgblawfirm.com
More informationEstate Planning in 2012
ESTATE PLANNING IN 2012 Overview and Goals of Estate Planning in 2012 Generally, there are three basic goals of estate, generation skipping transfer, and gift tax planning: (1) the reduction of estate
More informationA Guide to Estate Planning
BOSTON CONNECTICUT FLORIDA NEW JERSEY NEW YORK WASHINGTON, DC www.daypitney.com A Guide to Estate Planning THE IMPORTANCE OF ESTATE PLANNING The goal of estate planning is to direct the transfer and management
More informationWARRANTS, OPTIONS & OTHER INCENTIVES IN BUSINESS TRANSACTIONS
WARRANTS, OPTIONS & OTHER INCENTIVES IN BUSINESS TRANSACTIONS First Run Broadcast: February 9, 2015 Live Replay: August 7, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes)
More informationDouble Discounted Transfers
Advanced Markets planning perspective estate planning Double Discounted Transfers The Silver Lining After the Economic Downturn It seems clear that estate taxes are here to stay. For people who are likely
More informationWEALTH STRATEGIES. GRATs and Sale to IDGTs: Estate Freeze Techniques
WEALTH STRATEGIES THE PRUDENTIAL INSURANCE COMPANY OF AMERICA GRATs and Sale to IDGTs: Estate Freeze Techniques FREQUENTLY ASKED QUESTIONS ESTATE PLANNING How do two of the techniques used by wealthy clients
More informationALI-ABA Course of Study Charitable Giving Techniques
383 ALI-ABA Course of Study Charitable Giving Techniques Cosponsored by the ABA Section of Real Property, Trust and Estate Law and the ABA Section of Taxation June 10-11, 2010 New York, New York Charitable
More informationIssues AND. Tax-Powered Philanthropy: Doing well by doing good
Issues AND INSIGHTS February 2015 Tax-Powered Philanthropy: Doing well by doing good IN THIS ARTICLE Higher tax rates offer greater potential savings from charitable giving Strategies such as outright
More informationJeffrey P. Geida Weinstock Manion 1875 Century Park East, Suite 2000 Los Angeles, CA Tel: (310) Fax: (310)
Jeffrey P. Geida Weinstock Manion 1875 Century Park East, Suite 2000 Los Angeles, CA 90067 Tel: (310) 553-8844 Fax: (310) 553-5165 jgeida@weinstocklaw.com IRC 170(c), a contribution or gift to or for the
More informationEstate and Gift Tax Planning Opportunities for 2009
01.13.09 Estate and Gift Tax Planning Opportunities for 2009 Although financial markets are as confused, depressed and frozen as they have been in the lifetimes of most living Americans, clients should
More informationLeaving a Legacy. Your Guide to Charitable Giving
Leaving a Legacy Your Guide to Charitable Giving About Stifel Stifel is a full-service Investment firm with a distinguished history of providing securities brokerage, investment banking, trading, investment
More informationTAX & TRANSACTIONS BULLETIN
Volume 25 U.S. Families have accumulated significant wealth in their IRA accounts Family goals are to preserve this IRA wealth Specific Family goals for IRAs include: keep assets within the Family protect
More informationCHAPTER FOURTEEN. EXISTING QPRTs COMMON SITUATIONS AND OPTIONS. November James A. Flaggert
CHAPTER FOURTEEN EXISTING QPRTs COMMON SITUATIONS AND OPTIONS November 2011 James A. Flaggert Davis Wright Tremaine LLP 1201 Third Avenue, Suite 2200 Seattle, WA 98101 Phone: (206) 757-8044 Fax: (206)
More informationTax Bulletin: 2017 Year-End Tax Planning Considerations
Tax Bulletin: 2017 Year-End Tax Planning Considerations PAUL F. NAPOLEON, Senior Vice President & Head of Tax Services On December 2, 2017, the full Senate passed its amended version of the Tax Cuts and
More informationESTATE PLANNING WITH ANNUITIES & FINANCIAL PRODUCTS
ESTATE PLANNING WITH ANNUITIES & FINANCIAL PRODUCTS First Run Broadcast: August 11, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes) Estate planning and complex financial
More informationEstate Planning Concepts
Estate Planning Concepts Hartman Private Law LLP 2009 2 Estate Planning Do you have or need an estate plan? Old Documents/Non-Georgia Documents Estate planning foundation Four primary estate planning documents
More informationThe. Estate Planner. A well-defined strategy Use a defined-value clause to limit gift tax exposure. Take the lead. Super trustee to the rescue
The Estate Planner November/December 2007 A well-defined strategy Use a defined-value clause to limit gift tax exposure Take the lead Minimize or even eliminate estate taxes with a T-CLAT Super trustee
More informationTaming the Planning B.E.A.S.T.
Taming the Planning B.E.A.S.T. Tulsa Estate Planning Forum October 9 th, 2017 James M. Duggan, M.B.A., J.D. DUGGAN BERTSCH, LLC 303 West Madison, Suite 1000 Chicago, Illinois 60606-3321 e-mail: jduggan@dugganbertsch.com
More informationTRUST AND ESTATE PLANNING GLOSSARY
TRUST AND ESTATE PLANNING GLOSSARY What is estate planning? Estate planning is the process by which one protects and disposes of his or her wealth, sometimes during life and more often at death, in accordance
More informationAdvanced Wealth Transfer Strategies
Family Limited Partnerships (FLPS) Advanced Wealth Transfer Strategies The American Taxpayer Relief Act of 2012 established a permanent gift and estate tax exemption of $5 million, which is adjusted annually
More informationInvestment and Estate Planning Opportunities for High Net Worth Individuals in 2013
Investment and Estate Planning Opportunities for High Net Worth Individuals in 2013 Presented By: CPA, MST, AEP Keebler & Associates, May 2, 2013 Phone: (920) 593-1701 E-mail: robert.keebler@keeblerandassociates.com
More informationComprehensive Charitable Planning
Advanced Markets Client Guide Comprehensive Charitable Planning Charitable gifts that preserve personal wealth. Comprehensive Charitable Planning Giving to charity can provide many benefits and opportunities,
More informationCharitable Lead Trusts
Charitable Lead Trusts Michael V. Bourland, Jeffrey N. Myers, and Deren L. Worrell A. Attributes Of Charitable Lead Trusts ( CLTs ) 1. Payment Charitable Lead Interest. Annual (or more often) payments
More informationGregory W. Sampson Looper Reed & McGraw, P.C
Gregory W. Sampson Looper Reed & McGraw, P.C 469-320-6097 GSampson@LRMLaw.com www.lrmlaw.com 2010 Looper Reed & McGraw, P.C. The information contained herein is subject to change without notice Basic Estate
More informationEstate Planning. Uncertain Times. IRS Circular 230 Disclosure
Estate Planning IRS Circular 230 Disclosure To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments)
More informationHERMENZE & MARCANTONIO LLC ESTATE PLANNING PRIMER FOR SINGLE, DIVORCED, AND WIDOWED PEOPLE (New York)
HERMENZE & MARCANTONIO LLC ESTATE PLANNING PRIMER FOR SINGLE, DIVORCED, AND WIDOWED PEOPLE - 2018 (New York) I. Purposes of Estate Planning. A. Providing for the distribution and management of your assets
More informationCharitable Planning CLIENT GUIDE
Charitable Planning CLIENT GUIDE CHARITABLE PLANNING Giving to charity can provide many benefits and opportunities, both to the charity and to you. The charity, benefits from a donation that can help further
More information2017 Tax Cuts and Jobs Act
2017 Tax Cuts and Jobs Act The most significant changes in tax law since the 1986 tax reform were enacted in December 2017. The following charts detail the provisions most relevant to high income and high-net-worth
More informationUnderstanding the Transfer Tax and Its Impact on Estate Planning
Understanding the Transfer Tax and Its Impact on Estate Planning 2016 Skills Training for Estate Planners Sponsored by the Real Property, Trust and Estate Law Section of the American Bar Association New
More informationThe Use of Pass-Through Entities in Asset Protection and Wealth Transfer Planning
The Use of Pass-Through Entities in Asset Protection and Wealth Transfer Planning DANIEL W DALY III 2323 S. Shepherd, 14 th Floor Houston, TX 77019 713-979- 4701 daly@ohdlegal.com www.ohdlegal.com Judge
More informationUsing Advanced Irrevocable Trusts for Income and Estate Tax Savings: Making 2012 Count
Using Advanced Irrevocable Trusts for Income and Estate Tax Savings: Making 2012 Count The next nine months are an exceptional window of opportunity for your clients to make family wealth transfers. The
More informationWealth Transfer Planning in 2012: Perfect Storm of Opportunity
Wealth Transfer Planning in 2012: Perfect Storm of Opportunity 04.23.2012 04.23.2012 NEWS BY: FARHAD AGHDAMI 2012 may present the single greatest opportunity for wealth transfer planning in recent memory.
More informationWhat s Hot In Charitable Planning? Janet Bandera, J.D., rated AV Preeminent
What s Hot In Charitable Planning? Janet Bandera, J.D., rated AV Preeminent BANDERA LAW FIRM, PA Illinois Florida Missouri 941-345-4073 or jbandera@banderalawfirm.com Copyright by Bandera Law Firm, P.A.
More informationCLIENT ALERT - ESTATE, GIFT AND GENERATION-SKIPPING TRANSFER TAX
CLIENT ALERT - ESTATE, GIFT AND GENERATION-SKIPPING TRANSFER TAX January 2013 JANUARY 2013 CLIENT ALERT - ESTATE, GIFT AND GENERATION-SKIPPING TRANSFER TAX Dear Clients and Friends: On January 2, 2013,
More informationFrom Lindsey W. Duvall. Duvall Law Firm, LLC. 147 Old Solomons Island Road Suite 306 Annapolis MD
Uncovering Charitable Planning Opportunities Volume 7, Issue 11 Charitable giving is discretionary spending. It is affected by both the economy and the income tax rates. Not surprisingly, charitable giving
More informationSelected Subchapter J Subjects: From the Plumbing to the Planning, Preventing Pitfalls with Potential Payoffs January 24, 2018
Selected Subchapter J Subjects: From the Plumbing to the Planning, Preventing Pitfalls with Potential Payoffs January 24, 2018 Alan S. Halperin Paul, Weiss, Rifkind, Wharton & Garrison LLP Amy E. Heller
More informationPREPARING GIFT TAX RETURNS
PREPARING GIFT TAX RETURNS I. Overview A sample 2014 gift tax return illustrating several different types of gifts is attached at Tab A. The instructions for the 2014 gift tax return can be found at Tab
More informationWILLMS, S.C. LAW FIRM
WILLMS, S.C. LAW FIRM TO: FROM: Clients and Friends of Willms, S.C. Attorney Andrew J. Willms DATE: October 15, 2012 RE: Year-End Tax Planning for 2012 As you are probably well aware, most of the changes
More informationFederal Estate and Gift Tax and Use of Applicable Exclusion Amount 3. Pennsylvania Inheritance Tax 5. Gifting Techniques 6
Prepared by Howard Vigderman Last Updated August 8, 2016 Federal Estate and Gift Taxes, Pennsylvania Inheritances Taxes and Measures to Reduce Them 2 Even with the federal estate tax exemption at an historically
More informationEstate Planning under the New Tax Law
Tax, Benefits, and Private Client JANUARY 2018 NO. 1 Estate Planning under the New Tax Law This client alert is part of a special series on the Tax Cuts and Jobs Act and related changes to the tax code,
More informationPLANNING WITH FAMILY LIMITED PARTNERSHIPS/FAMILY LLCS, PART 1 & PART
PLANNING WITH FAMILY LIMITED PARTNERSHIPS/FAMILY LLCS, PART 1 & PART 2 First Run Broadcast: October 15 &16, 2013 Live Replay: January 15 & 16, 2014 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00
More informationA WILL IS NOT ENOUGH by Kelly A. Thompson
A WILL IS NOT ENOUGH by Kelly A. Thompson kelly@twplc.com DISCLAIMER: This outline is for information purposes only and is not a substitute for legal counsel. assumes no liability for errors or admissions,
More informationContents. Foreword Acknowledgments Introduction
Contents Foreword Acknowledgments Introduction Chapter 1 Brief History Of The Estate Tax And The Marital Deduction 1 1.1 Historical Background Of The Federal Estate Tax And The Marital Deduction 1 1.2
More informationEstate Planning Strategies for the Business Owner
National Life Group is a trade name of of National Life Insurance Company, Montpelier, VT and its affiliates. TC74345(0613)1 Estate Planning Strategies for the Business Owner Presented by: Connie Dello
More informationEstate Planning for IRAs & Qualified Plans
Estate Planning for IRAs & Qualified Plans Presented by Robert S. Keebler, CPA/PFS, MST, AEP Keebler & Associates, LLP All Rights Reserved 1 Outline Foundation Concepts 401(a)(9) Regulations Estate Planning
More informationABC s of Family Succession Planning
ABC s of Family Succession Planning By: Charles F. Adler Schneider, Smeltz, Ranney & LaFond, P.L.L. 1111 Superior Avenue, Suite 1000 Cleveland, OH 44114 (216) 696-4200 CAdler@ssrl.com Common Issues Financial
More informationRecent Developments in the Estate and Gift Tax Area. Annual Business Plan and the Proposed Regulations under Section 2642
DID YOU GET YOUR BADGE SCANNED? Gift & Estate Tax Recent Developments in the Estate and Gift Tax Area Annual Business Plan and the Proposed Regulations under Section 2642 #TaxLaw #FBA Username: taxlaw
More information